Implemented on January 1, 2022, the Provisions of the People's Republic of China on the Administration of Registration of Overseas Manufacturers Producing Imported Food (GACC Order No. 248) explicitly requires all overseas enterprises involved in the production, processing, and storage of food intended for export to China to obtain registration with the GACC (this excludes enterprises related to food additives and food-related products).
I. Registration Conditions and Procedures
(I) Registration Criteria
1. The food safety management system of the country (region) where it is located has passed the equivalence assessment and review of the GACC;
2. Established with the approval and under the effective supervision of the competent authority of the country (region) where it is located;
3. The overseas manufacturers of imported food shall establish an effective food safety and health management and protection system, legally produce and export products in the countries (regions) where they are located, and ensure that the food exported to China complies with relevant Chinese laws and regulations and national food safety standards;
4. Meet the relevant inspection and quarantine requirements agreed by the GACC and the competent authorities of the country (region) where it is located.
(II) Registration Procedures
Including two categories: recommended by the competent authorities of the country (region) where it is located and the application for registration by enterprises.
Recommended registration by the competent authority of the country (region)
(III) Necessary Application Materials
1. Letter of recommendation from the competent authority of the country (region);
2. List of enterprises and application for enterprise registration;
3. Enterprise identity documents, such as the business license issued by the competent authority of the country (region);
4. A statement from the competent authority of the country (region) stating that the recommended enterprise meets the requirements of these provisions;
5. A review report of the review inspection of the enterprise by the competent authority of the country (region).
When necessary, the GACC may request enterprise food safety and hygiene and protection system documents, such as the plan of enterprise factory, workshop and cold storage, process flow diagram, etc.
(IV) Application Materials Required for Enterprise Registration
1. Enterprise Registration Application Form;
2. Enterprise identity documents, such as the business license issued by the competent authority of the country (region);
3. Statement of commitment to complying with the requirements of these Provisions;
(V) Validity Period of Registration
The registration validity is 5 years. If an overseas manufacturer of imported food needs to extend its registration validity, it shall submit an extension application and a declaration confirming continued compliance with registration requirements to the GACC via the designated application channel, within 3 to 6 months before the registration expires.
Reminder: When a registered enterprise exports food to China, it shall mark its Chinese registration number or the registration number approved by the competent authority of the country (region) on the inner and outer packages of food.
II. Registration Administration
Within the validity period of registration, if the registration information of overseas manufacturers of imported food changes, the overseas manufacturers of imported food concerned shall submit an application for change to the GACC through the registration application channel, and submit the following materials:
(I) Comparative table of changes in registration details;
(II) Supporting documents related to the changes.
If the GACC considers that it can be changed after evaluation, the changes shall be approved.
If the production facility is relocated, the legal representative changes, or the registration number assigned by the host country (region) is altered, a new registration application must be lodged, leading to the automatic nullification of the registration number in China.
III. Important Considerations
If a registered overseas manufacturer of imported food has any of the following circumstances, the GACC shall cancel its registration and make an announcement:
(I) Major food safety accidents of imported food occur due to the enterprise's own reasons;
(II) Food safety problems are found in the entry inspection and quarantine of food exported to China, and the circumstances are serious;
(III) There are major problems in the food safety and health management of the enterprise, and the enterprise cannot guarantee that its exported food to China meets the safety and health requirements;
(IV) The enterprise still does not meet the registration requirements after rectification;
(V) Submission of false materials or concealment of pertinent information;
(VI) The enterprise refuses to cooperate with the GACC in re-inspection and accident investigation;
(VII) The enterprise leases, lends, transfers, resells or fraudulently uses the registration number.
IV. FAQ
Q: Which overseas food production enterprises are recommended for registration by the competent authorities from their respective countries (regions) to the GACC?
A: There are a total of 18 categories, which include: meat and meat products, casings, aquatic products, dairy products, bird’s nests and bird’s nest products, bee products, eggs and egg products, edible oils and fats, oilseeds, stuffed pastry products, edible grains, milled grain industry products and malt, fresh and dehydrated vegetables and dried beans, condiments, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, foods for special dietary purposes, and health foods. For product categories that fall outside these 18, companies must apply for registration independently.
Q: The quality of wine from overseas Company A is excellent, and our company wishes to collaborate with them to penetrate the Chinese market. How can we verify the credentials of Company A?
A: The GACC shall uniformly publish the list of registered overseas manufacturers of imported food. You can visit the website of the "Bureau of Import and Export Food Safety of GACC" (http://jckspj.customs.gov.cn/) and search under the "Information Service-Registration of Overseas Manufacturers of Imported Food-Registration List of Overseas Manufacturers of Imported Food" section.
Q: Our company has secured the registration for an overseas manufacturer of imported food. We have recently introduced several new snacks and want to expand into the Chinese market immediately.
A: Don't worry~ Not only must overseas manufacturers of imported food obtain registration with the GACC, but the categories of imported products must also fall within the product categories registered by the company! Product categories that have not yet obtained registration must be registered prior to importation.
That's it for today's customs mini-lesson! Have you mastered the correct approach to the Provisions on the Administration of Registration of Overseas Manufacturers Producing Imported Food? If you have any other questions, feel free to call the customs hotline at 12360 for assistance~
Disclaimer：The above content is translated from Chinese version of Huangpu Customs 12360. The Huangpu Customs 12360 version shall prevail.