On April 12, 2021, the China GACC (General Administration of Customs of China) announced the implementation of the Administrative measures for the registration of overseas manufacturers for imported food products (GACC Order No.248). This will require all food exporters to China to register with GACC, marking a big change from the previous requirements where only 4 categories were required to be registered. On November 5, 2021, the China GACC issued an explanatory document for China food importers to learn more about the expected requirements in January 2022.
| Before | From January 2022 onwards | |
| Overseas production enterprises need to be registered | Only meat products, aquatic products, dairy products and bird’s nest products overseas production enterprises | All food production enterprises (excluding food additives and food-related products) |
| Method of Registration | Recommended registration only | Recommended registration for overseas production enterprises of 18 food types. Simplified self-registration for other food types. |
| Validity period | 4 years | 5 years |
| Renewal application | One year before the expiration of the registration validity period, through the competent authority of the country (region) where it is located or other prescribed methods. | Within 3 to 6 months before the expiration of the registration validity period, through the registration application process path, submit an application for renewal of registration to the General Administration of Customs |
- The prerequisites for an overseas production enterprise of imported food to obtain registration qualification:
- the country (region) where the enterprise is located meets the requirements;
- the enterprise’s own qualifications should be legally controlled in the country (region) where it is located;
- the enterprise ‘s own safety and health management status should meet the requirements, and its production and export should meet the requirements of the country (region) where it is located. When the enterprise exports food to China, it should comply with relevant Chinese laws and regulations and national food safety standards;
- for supplementary requirements, enterprises should also meet the relevant inspection and quarantine requirements agreed upon by the GACC and the competent authority of the country (region) where the enterprise is located.
- Registration application materials can be submitted in Chinese or English, and the registration application webpage (http://spj.customs.gov.cn/cifer/) is also bilingual in Chinese and English.
- As for the self-registration, the application can be submitted by themselves or entrust an agent. The entrusted agent can be domestic/overseas organizations/individuals that comply with local laws and regulations. Power of Attorney is needed. For self-registration, the application materials include:
- application form
- corporate identity certificate, e.g., business license
- a statement that the company promises to meet the requirements
- During the application duration, GACC will organize an evaluation team to conduct review by itself or by entrusting relevant agencies. During the validity period of the registration, GACC may conduct re-examinations as needed. All of review work require the assistance of the application enterprise.
The GACC Order No.248 will be effective from January 1, 2022, onwards, and the Order No.243 previously issued on November 23, 2018 will be abolished and replaced accordingly.
By Gong Ying. Contact Cisema if you would like to learn more.
