Prepared for NZTE
July 2026 · Confidential
CHINA MARKET ENTRY
BRIEF & ASSESSMENT
Research, validation and strategic rationale for China market entry — prepared for NZTE engagement and Beachhead Advisor introduction
Prepared By
Tristan Vine, CEO & Co-Founder
Company
Mānuka Performance Limited
Stage
Growth — Live Export Operations
NZTE China Guide
Reviewed & Referenced
Executive Summary
WHERE WE ARE. WHERE WE'RE GOING. WHY CHINA. WHY NOW.

Mānuka Performance is a Māori-led New Zealand advanced bioactive nutrition company with live commercial operations in the United States and South Korea. We manufacture precision nutrition systems built on PolySure™ — a proprietary 7-polyphenol bioactive certification platform derived from New Zealand's native honey spectrum — verified to ISO-17025 and unlike anything available from NZ or global competitors.

This brief outlines our rationale for prioritising China as our third major export market, the specific channels and products we are targeting, the in-market engagement we have already undertaken, the capability and resource requirements we have assessed, and the compliance and regulatory landscape we have reviewed.

We are not approaching China from a standing start. We have NZ Embassy engagement in Beijing, CBEC channel conversations underway, and direct peer learnings from Two Islands (via Julia) whose China CBEC model closely mirrors our intended approach. We are ready to move from assessment to execution — and we are seeking an experienced in-market advisor's input to stress-test our assumptions and refine our go-to-market approach.

Key Thesis
China is New Zealand's largest export partner by value (NZD$19.3B annually). NZ-origin health and nutrition products carry significant provenance premium with Chinese consumers. Our product architecture — compact, daily-use sachet format, science-verified bioactive profile, FernMark certified — is purpose-built for the CBEC health channel. The window for NZ science-backed nutrition brands to establish credibility in this market is open now.
Strategic Rationale
WHY CHINA. WHY NOW. WHY IT FITS OUR STRATEGY.
Rationale 01
De-risking USA Concentration

Our primary market is the USA. Given current geopolitical and trade policy uncertainty — including tariff risk and shifting bilateral relationships — over-reliance on a single export market carries meaningful strategic risk. China is not a pivot away from the US. It is a deliberate, portfolio-based hedge that strengthens our overall export resilience.

Rationale 02
Natural Complement to Korea

South Korea has given us operational infrastructure, Asian market regulatory familiarity, CBEC-compatible product formats, and export logistics capability that directly reduce China entry risk. The same compact sachet format performing in Korea's endurance market translates directly to China's health consumer CBEC channel. Korea and China are sequential, not competing.

Rationale 03
NZ's Largest Export Partner

China accounts for NZD$19.3B in NZ annual exports — our single largest trading partner. NZ's food safety reputation, FernMark provenance credibility, and clean-green brand equity are deeply trusted by Chinese health consumers. We are not entering an unfamiliar market. We are leveraging NZ's most established trading relationship.

Rationale 04
Product-Market Fit Is Demonstrated

China's CBEC gut health and premium wellness supplement market exceeds $12B. NZ-origin probiotics, bioactive honey, and gut health products are actively sought by Chinese consumers and CBEC operators. GI-PRO™ — our gut health system combining Mānuka bioactive matrix with BC30™ (2 billion CFU, FDA GRAS) — maps precisely to this demand.

In-Market Engagement to Date
THIS IS NOT A STANDING START.

We want to be direct: thorough in-market preparation matters, and we have taken that seriously. The following summarises the substantive in-market engagement and research we have completed prior to this brief.

Trip 1 — Beijing, Xi'an, Chengdu & Hong Kong
Our first China trip centred on the NZ Embassy in Beijing, who connected us directly with Accestra Consulting for a dedicated working session on China's Food Safety National (GB) Standards architecture — the regulatory tree running from the Food Safety Law through GB standards (GB 7101 Beverages, GB/T 10789, GB 2760 additives, GB 14880 fortifiers) down to product-level requirements, plus the three-step importation procedure and GACC's overseas manufacturer registration regime (Decree 248, superseded by Decree 280 from 1 June 2026). In Beijing we also visited Zhongguancun Life Science Park and held government-level meetings with officials and other nutraceutical stakeholders there. The wider delegation then took in business programme time in Xi'an and Chengdu, before a final leg in Hong Kong where we met directly with NZTE. This gave us regulatory literacy and a first cross-city read on the market before we built any commercial plan.
Trip 2 — Shanghai / Guangzhou / Shenzhen
A second, funded delegation (Asia NZ Foundation, Dec 2025) took us through the NZ Consulate & Health Sector Roundtable and a ChemLinked/Reach24H regulatory briefing in Shanghai, site visits including Hongqiao Pinhui live-commerce base and Tatua Dairy Products, the Jinan University research centre and a manufacturer visit in Guangzhou, and the Healthplex Expo in Shenzhen. This is where our two live in-market relationships — Jinan University and Narnia Biotechnology — were established.
CBEC Channel Conversations
We have had active conversations with CBEC platform operators regarding GI-PRO™ listing requirements, compliance documentation, and product positioning. We understand the CoA, FernMark, and NZ-origin documentation requirements for Tmall Global and JD Worldwide health category listings.
Two Islands — Peer Learning
I have spoken directly with Julia at Two Islands about their China CBEC model. Their experience navigating platform relationships, consumer trust-building through provenance storytelling, and compliance requirements has been directly instructive. We understand an NZTE Beachhead Advisor supported their strategy and that this kind of input was valuable in shaping their approach.
NZTE China Market Guide
We have reviewed the NZTE China Export Guide in full. The market structure, CBEC regulatory environment, distribution channel landscape, and compliance framework outlined have been incorporated into our channel strategy and resource planning.
Jinan University Research Relationship
Two live connections from the Guangzhou leg: the China–New Zealand Joint Research Centre for Food Safety & Nutrition (Tianhe campus), and the International Joint Laboratory for Modernization of Traditional Chinese Medicine and Innovative Drug Research (Panyu campus, formal roundtable). This is a genuine complement to our NZ-side science base — the Bioeconomy Science Institute's Biodiscovery Platform and related He Ara Whakahihiko funding streams establish what our bioactive does; a Jinan University collaboration is the route to establishing that it holds up under Chinese clinical scrutiny, on Chinese subjects, published through a Chinese institution. This is currently a research relationship, not yet a formalised MOU — an area we would value input on sequencing correctly.
Narnia Biotechnology — B2B & Food Service
Guangzhou-based importer & distributor (narniabiotech.com), site visit completed. Two distinct interest areas: our PolySure™-certified bioactive honey matrix as a B2B ingredient supply for other manufacturers' formulations, and separately, honey as a functional ingredient input for bubble tea and RTD beverage manufacturers — a large, fast-moving food-service category. Both sit outside the Blue Hat health food registration track entirely, governed by general trade and GB additive/ingredient standards rather than GB 16740. This gives us a materially faster-to-activate channel running in parallel to CBEC.
Korea Operational Learnings — A Complement, Not a Template
Our South Korea channel has provided direct learnings on Asian market export logistics, sachet format performance, CBEC-adjacent distribution, and consumer positioning for NZ-origin bioactive products. We want to be precise about what this does and doesn't tell us: Korea is a single market of ~52M people with one language and one dominant e-commerce logic, closed via one exclusive distributor relationship. China is not a bigger version of that — it is a federation of consumer economies where Shanghai, Guangzhou and Shenzhen each behave differently. Korea proves we can close a distributor deal and hit KPI-based milestones. It is evidence of our execution capability, not a model for how China's channel mix or timeline will behave.
R&D Pathway
BSI IN NZ, JINAN UNIVERSITY IN CHINA — ONE CREDIBILITY CHAIN.

We see our domestic and China-facing science tracks as sequential layers of the same trust architecture, not competing priorities.

NZ Side — BSI

The Bioeconomy Science Institute's Biodiscovery Platform and the He Ara Whakahihiko funding streams are our domestic R&D and validation base — where formulation science and PolySure™'s underlying polyphenol tracking get funded and peer-reviewed on home soil. This is the platform that produces defensible, publishable science.

China Side — Jinan University

The China–New Zealand Joint Research Centre for Food Safety & Nutrition, and the International Joint Laboratory for Modernization of Traditional Chinese Medicine, give us a route to Chinese-soil clinical data — the credibility layer that matters for Chinese HCP, telehealth and regulatory audiences in a way NZ-only data doesn't automatically transfer.

Why This Matters for Registration
A Jinan University co-authored study is the Chinese-market equivalent of the HCP trust signal our Dr Marc Stevens MD credential provides in the US. It's also directly relevant should we pursue a Registration-type (non-nutrient) Blue Hat application in future, where dossier requirements explicitly call for domestic and international research and safety assessment data.
Geographic Focus
CITIES AS MARKETS — NOT "CHINA" AS ONE MARKET.

Each of the three cities on our second delegation is, on its own, a larger consumer economy than most single countries we will ever enter. Our approach is to name two or three anchor cities and go deep, not spread thin chasing national coverage.

Shanghai
Commercial / CBEC anchor

NZ Consulate relationship, Hongqiao Pinhui live-commerce infrastructure, highest CBEC platform density. Natural launch city for Tmall Global / JD.

Guangzhou
B2B / GBA gateway

Jinan University research relationship, manufacturer contacts, and Narnia Biotechnology — the B2B ingredient and Greater Bay Area distribution node.

Shenzhen
Category intelligence

Healthplex Expo access gives ongoing category and competitor visibility — a standing intelligence channel rather than a near-term commercial focus.

Market Entry Approach
A TRUSTWORTHY LOCAL PARTNER, NOT AN IN-HOUSE CHINA TEAM.

Rather than building China capability in-house, our approach is to appoint a partner who already is the ecosystem, and let them localise positioning and drive consumer pull-through through strategic influencer relationships at a speed and cultural fluency we cannot replicate from Whakatāne. We retain what compounds in value — store accounts, trademarks, and first-party data — regardless of which partner we appoint. This is one of the specific questions we want to work through with NZTE: how to evaluate and sequence a TP agency or distribution partner relationship correctly for a company at our stage.

A Point Worth Stating Clearly
We do not sell honey. We sell a validated bioactive matrix — NZ native honeys carrying seven ISO-17025-verified polyphenol markers under our PolySure™ standard — used as a functional carrier for probiotics, gut health actives, and performance nutrition. This distinction is the core of our positioning in every channel, but it matters most in food service: any partner can source commodity honey. What we offer is a science-backed, provenance-anchored ingredient with a defensible point of difference that a commodity supplier cannot replicate.
Market Opportunity
WHAT WE ARE TARGETING AND WHY.
NZD$19.3B
NZ annual exports to China — our largest trading partner
$12B
China CBEC health supplement market (USD)
12,000+
Active CBEC health product operators in China
8.9%
Adult obesity prevalence — growing metabolic health market
CHANNEL 01 — CBEC Consumer: GI-PRO™ Gut Health
In Development

China's cross-border e-commerce health and supplement category is the primary entry point. Chinese consumers actively seek NZ-origin gut health and immune support products — NZ provenance is a genuine purchase driver, not merely a label claim. GI-PRO™ is our designed CBEC launch SKU: compact daily-use sachet, FernMark certified, ISO-17025 verified bioactive honey matrix, BC30™ probiotic (2 billion CFU, FDA GRAS), with an active RCT providing clinical credibility.

Our target platforms are Tmall Global and JD Worldwide. We have reviewed listing requirements, understand the CBEC regulatory documentation needed (CoA, FernMark, NZ MPI compliance), and have had initial operator-level conversations. Pricing is positioned at a significant premium to domestic Chinese alternatives — consistent with NZ-origin health product positioning across the platform.

TBD
CBEC Revenue Target Y1 — to be modelled
TBD
CBEC Revenue Target Y2 — to be modelled
TBD
CBEC Revenue Target Y3 — to be modelled
Tmall Global + JD
Primary CBEC Platforms
CHANNEL 02 — B2B Ingredient & Food Service Supply
In Development

Parallel to the consumer CBEC channel, we are targeting the Chinese nutraceutical manufacturing and food service sector as a B2B ingredient customer. We supply PolySure™-certified bioactive honey formulation systems — not commodity ingredients. Each batch carries an ISO-17025-compliant Certificate of Analysis verifying seven polyphenol markers. This standard is not currently available from other NZ honey suppliers to this market, and positions us as a premium, differentiated ingredient partner rather than a price-competitive commodity supplier.

Narnia Biotechnology (Guangzhou-based importer & distributor) has expressed genuine interest across two distinct sub-channels: PolySure™ as a raw ingredient input for other manufacturers' formulations, and separately, honey as a functional sweetener/ingredient input for bubble tea and RTD beverage manufacturers — a large, fast-moving category. Both sit outside Blue Hat health food registration entirely, governed by general trade and GB additive/ingredient standards, making this channel materially faster to activate than any CBEC consumer SKU.

Our target accounts include supplement contract manufacturers, functional food and beverage brands, and food service operators in our anchor cities (Guangzhou/GBA primarily) seeking NZ-origin bioactive ingredients with verifiable quality credentials. Anchor account target: 3–5 contracts by end of Year 2.

TBD
B2B Revenue Target Y1 — to be modelled
TBD
B2B Revenue Target Y2 — to be modelled
TBD
B2B Revenue Target Y3 — to be modelled
3–5
Target anchor accounts Y2
Combined China Revenue Projection
We haven't put specific numbers against a combined CBEC and B2B ingredient forecast yet — this is exactly the kind of modelling we want to work through properly, with informed input on realistic channel ramp, pricing, and account timing, rather than presenting an unvalidated figure.
Regulatory & Compliance Assessment
WHAT WE UNDERSTAND. WHAT WE NEED TO VALIDATE.

We recognise that China presents a materially different regulatory and operating environment from South Korea and the United States. The following reflects our current understanding, and the specific areas where an experienced in-market advisor's input would be most valuable in stress-testing our approach.

CBEC Regulatory Framework
We understand the CBEC (跨境电商) regulatory framework allows NZ-origin health products to be sold to Chinese consumers via cross-border platforms without China domestic registration — provided GACC registration, correct product categorisation, and appropriate labelling are in place. We have reviewed these requirements and believe GI-PRO™ qualifies under the food/health food CBEC category.
Product Documentation
ISO-17025 Certificate of Analysis per batch, NZ MPI export certificates, FernMark licensing documentation, FDA GRAS status (BC30™), and Informed Sport pathway in progress. We believe our documentation package is materially stronger than most NZ CBEC entrants in this category.
Labelling Requirements
We understand CBEC products require Chinese-language product information, ingredient listing, and dosage instructions appropriate to the platform. We have budgeted for professional translation and China-market label design as part of our entry investment.
B2B Ingredient Compliance
For the B2B ingredient channel, we understand that ingredient supply into Chinese manufacturing requires supplier qualification, GACC facility registration (or NZ-side export certification), and in some cases category-specific approval. This is an area where we would specifically value input on the most efficient pathway for a company at our scale.
Trademark — "Zero Secret" (China IP Stack)
"Zero Secret" has been specifically developed as a China-facing consumer brand — part of a dedicated IP stack built to protect Mānuka Performance in this market rather than an extension of our NZ or US branding. We are actively working to secure the full trademark position: the Class 30 (goods) registration — covering condiments, cereal, candy, honey and snack categories — has already been secured via a notarised transfer to Manuka Bioactives Limited (5 Nov 2024, valid to 2034). We are now progressing the Class 35 (services) registration, covering retail, e-marketplace and advertising use, alongside a coexistence check against a separate Chinese-character mark in the same class. This is a live, resourced workstream rather than an open gap.
Areas Requiring Validation
Specific probiotic import classification under CBEC vs standard import rules; optimal entity structure for receiving RMB payments; WFOE vs rep office vs distributor model for B2B channel; platform operator contract and margin structure on Tmall Global and JD. These are the specific questions we want to work through with NZTE and an experienced in-market advisor.
Known Risks — Openly Acknowledged
We are not entering China without clear eyes on the risks: regulatory change risk in the CBEC environment; platform dependency on Tmall/JD operator relationships; IP protection in the formulation supply context; currency and payment repatriation; and geopolitical bilateral risk between NZ and China. Our mitigation approach — CBEC-first, asset-light, dual-channel — is designed to limit capital exposure while we validate the market.