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FAQs of GACC Registration

  

FAQs-Frequently Asked Questions of GACC Registration

☼  We did not apply for registration before, why can find our company's GACC registration number?

Answer: It should be that the Chinese importer was unable to contact the manufacturer during Customs clearance before, so registered without your authorization;

☼  Why are there multiple GACC registration numbers of our company?

Answer:  A lot of data in the GACC system comes from previous AQSIQ registrations. Multiple GACC registration numbers should be registered in the old AQSIQ system by different Chinese importers before without your authorization;

☼  If I can find our company's GACC registration number, does that mean I don't need to register again?

Answer: In most cases, you still need to register again
1) If this GACC registration number is not registered by yourself recently , you need to re-register in the new GACC system;
2) If this GACC registration number was registered by yourself in the old AQSIQ system before, but the AQSIQ user ID and password can log in to the new GACC system, then you need to re-register in the new GACC system;
3) If your product belongs to the 18 risky food categories specified by GACC 248 Degree, you also need to apply for the GACC recommended registration process separately;

☼  Is GACC registration and AQSIQ registration the same?

Answer: It is not the same. Because of the reorganization of the Chinese government, AQSIQ has been abolished in 2018. After 2018, the registration of all overseas food manufacturers and exporters will be transferred to GACC registration;

☼  What is the cost and timeline of GACC registrations?

Answer: Different type GACC registration have different cost and timeline;
1. General GACC registration for manufacturers or exporters is about $500,time about 2 weeks;
2. GACC registration for medium-risk foods producers is about $1000,time about 2-4 months
3. GACC registration for high-risk foods producers is $5K to 30K, time about 6-12months;
For details, please visit: "GACC registration price"

☼  What kind GACC registrations are required for overseas food manufacturers?

Answer: Different food categories require different GACC registrations. For details, please visit: "What kind GACC registrations are required for overseas food manufacturers?"

☼  We are manufacturer, our products export to China directly by us, How do I apply for GACC registration?

Answer: You need to submit at least two GACC applications , one is General GACC registration for Overseas Exporters , the other is General GACC registration for Overseas Manufacturer;

If your products involves medium-to-high-risk food category, your also need to apply anther recommendation application process of the competent authority of your country

☼  What is CRA?

CRA is the abbreviation of ”China Representative Agent“, also known as "China Responsible Agent"; When overseas manufacturers or exporters apply to the Chinese government for registration, certification, permits, etc., Usually will be required to authorize a CRA to handle it;

This is a common international practice. For example, when applying for US FDA registration, needs to designate a ”U.S. Agent“ ; when applying for CE certification to the European Union, need to designate an EAP (European Authorised Representative);

Because overseas applicants do not understand the local language, nor are they familiar with local regulatory requirements, technical specifications, and handling procedures;And,If there are problems in the application process that needs to be communicated and resolved, it is also very difficult for local government officials to directly contact distant overseas applicants for communication;

Therefore, government agencies of various countries usually require overseas applicants to authorize a professional third-party agency to handle the relevant procedures;

☼  Why is it not recommended to choose an importer as your CRA?

GACC usually recommends that overseas applicants apply for GACC registration, especially for producer involving medium and high-risk food categories, entrust a professional third-party CRA company to handle the register process, rather than non-professional temporary importers or Chinese buyers;

CRA is usually responsible for the following responsibilities:

1. Act as a liaison between foreign applicants and GACC to ensure normal and timely communication between the two parties;
2. Faithfully and accurately convey the relevant regulations and technical requirements of GACC registration to overseas applicants;
3. Assist overseas applicants to prepare GACC registration application documents to ensure that they meet the requirements of Chinese regulations and technical standards;
4. During the GACC registration process, communicate with GACC officials to solve the problems encountered during the registration process,to ensure the smooth progress of GACC registration;;
5. Assist GACC or CNCA officials in the on-site inspection of the applicant's overseas production facilities (if necessary);
6. During the 5-year validity period of GACC registration, if it involves changes in regulations or changes in registration matters, etc., assist overseas applicants in handling;
7. Assist overseas applicants in renewal procedures before the 5-year validity period of GACC registration expires;

In particular, the GACC registration for medium- and high-risk food production enterprises, requires the producer comply with Chinese regulations and technical requirements for the corresponding food category. Applicants must provide production facility quality management system documents (similar to HACCP, GMP ISO 22000, etc.) to GACC for review, and each type of food category has different requirements, and some high-risk food categories also require GACC-CNCA Officials go to overseas production facilities to conduct on-site inspections,

Therefore the CRA must be proficient in GACC registration regulations and professional technology; But the professional focus of importers is not on this point, their expertise is trade rather than production technology management. If a non-professional CRA submits unqualified application materials to the GACC, it may cause your factory to fail to complete the GACC registration, resulting in a waste of time and money. What's worse is the loss of the vast Chinese market, and the loss of time cost is even greater.

☼  What services does CRA provide?

 

The main service items that CRA provide:


1. Translation Service
1) The official language of China is only Chinese, and most of the official GACC documents are only in Chinese. The English materials you see are all translated into English by CRA;
Including: English version webpage for GACC registration, GACC regulations, GACC registration guidance documents, GACC registration application form, GACC application document template samples, etc.;
2) All the GACC application documents must have Chinese translation, and all these documents are translated into Chinese by the CRA;

2. Consultancy Services
1)The GACC official will not provide consulting services, let alone English consulting services. All the problems you encounter will be solved by the customer service staff of CRA;
2) Consulting services include: GACC registration type classification, food category classification, GACC application document list and template samples, customer service consultation before registration, technical support during the registration process, etc.;

3. Pre-review services
1) All GACC application documents submitted by applicants will be pre-reviewed by CRA‘s professionals before they are formally submitted to GACC to ensure that all application documents meet GACC standards;
2)If there are errors or defects in the application documents, CRA will notify and guide the applicant to correct them until they meet the GACC requirements;
3)During the formal GACC review process, if any problems are encountered, CRA will also help the applicant to communicate with GACC and solve them;

4. Regulatory compliance services
1) Different types of products imported into China need to comply with different Chinese regulations and standards. Some products may involve the approval of multiple government departments. These need to be resolved in advance before shipment. If the problem is discovered only after arriving at a Chinese port, it is It's too late
2) Compliance services include: product import compliance guidelines in China, product formula pre-review, Chinese label pre-review, product quality index pre-review, product testing and certification, product government registration and filing, etc.;

☼  What is the CRA charge price?

CRA service fee is according to different service items, the price is ranging from hundreds of USD to thousands of USD, you need to consult customer service staff for details;

☼  What documents need to be provided when registering 18 categories of food overseas manufacturers (GACC-1-2 & GACC-1-3 types)?

The competent authority of the country (region) where it is located should review and check the manufacturer recommended registration, and after confirming that it meets the registration requirements, recommend registration to the GACC and submit the following application documents:

(1) Recommendation letter from the competent authority of the country (region) where manufacturers are located;

(2) List of manufacturers and application of manufacturer registration;

(3) Manufacturer identification documents, such as business license issued by the competent authority of the country (region) where it is located;

(4) A statement recommended by the competent authority of the country (region) where the manufacturer meets the requirements of the regulations;

(5) The review report issued by the competent authority of the country (region) where the manufacturer is located for reviewing and checking the related manufacturers.

(6) If necessary, the GACC may request documents of the manufacturer's food safety, hygiene and protection system, such as the floor plans of the manufacturer's factory area, workshop and cold warehouse, as well as process flow diagrams.

It should be noted that, if risk analysis or evidence shows that the risk of a certain type of food has changed, the GACC may conduct registration methods and application documents for the corresponding food overseas manufacturers; if the registration methods and application documents are otherwise agreed between the related countries (regions) and China, it should be implemented in accordance with the agreement of both parties.

☼  What is the difference between GACC registration and AQSIQ registration? Do I need to register with GACC if I already have an AQSIQ registration number?

This is a very popular question, which is asked almost every day:

What is the difference between GACC registration and AQSIQ registration?

Do I need to register with GACC if I already have an AQSIQ registration number?

Let's make a detailed explanation here:

Items GACC AQSIQ
Government agency name General Administration of Customs of China General Administration of Quality Supervision, Inspection and Quarantine of China
Current state In force Cancelled in 2018
Registration of overseas food exporters Beginning in 2019,
currently under implementation
Started in 2012, has ended in 2019
Exporter registration number 11 digits (e.g. 03618000888) 11 digits (e.g. 41013000999)
Registration of Foreign food manufacturers (Low-risk food category) Beginning in 2019,
currently under implementation
Started in 2012, has ended in 2019
Manufacturers  registration number (GACC-1-1 type) 2019 to 2021 Transition period:
10 digits (e.g. 9364210888 )
From 2020:
18 digits (e.g. CTHA24022110201234)
10 digits (e.g. 9528210888 )
Registration of Foreign food manufacturers  (Medium-risk food category) Beginning in 2022-1-1,
Currently accepting applications
No such category
Manufacturers  registration number  (GACC-1-2 type) 18 digits (e.g. CTHA24022110201234) No such category
Registration of Foreign food manufacturers  (High-risk food category) Beginning in 2022-1-1,
Currently accepting applications
Started in 2012, has ended in 2020, CNCA is responsible for reviewing and issuing CNCA registration numbers
Manufacturers  registration number  (GACC-1-3 type) 18 digits (e.g. CTHA24022110201234) Depending on the country of origin, the number of digits is variable (e.g. NY12G0001 or AT60212EG)
Registration Validity Period 5 years 4 years

☼  What are the reasons cause GACC registration failure?



Some GACC applicants, want to save costs, do not entrust a professional third-party CRA to apply for GACC registration, but apply for GACC registration in the "single window" by themselves, but lead to a high failure rate, and in the end, they still neet to entrust a professional third-party CRA to solve the problem of GACC registration failure, finally, they not only did not save costs, but also waste a lot of time, resulting in export delays and greater losses;

We often receive urgent enquiries from GACC applicants:
"We have submitted an application for GACC registration in the single window, and it has been a long time, but it has not been approved, and we have received a response from GACC, what should I do?"

If the GACC registration application documents are correct, it will usually be approved by GACC in 1-2 weeks, or get GACC's reply for corrective action, if you have not received any reply from GACC, then there must be a problem in application process;

The most common reasons for registration failure are:

1. Wrong application type and category :
GACC registration is applied based on food categories. There are about 30 categories and 100 sub-categories in GACC-registered food categories. Each sub-category needs to apply for a separate GACC registration number. If the products of the manufacturer involve multiple categories, then they need to apply for multiple GACC registration numbers;

Different food categories need to apply for different types of China GACC registration,
There are 5 types GACC registrations:
1) GACC registration for overseas manufacturers of Low risk food ( GACC-1-1 type)
2) GACC registration for overseas manufacturers of Medium risk food ( GACC-1-2 type)
3) GACC registration for overseas manufacturers of High risk food ( GACC-1-3 type)
4) General GACC registration for overseas exporters of imported food ( GACC-2-1 type)
5)  GACC-CIQ registration for Chinese importers of imported food ( GACC-3-1 type)

2. Wrong classification for products listing :
GACC registration requires the listing of foods exported to China, and needs to fill in China’s HS code and CIQ code. The classification rules of foods in China and the country of origin may be different. Wrong classification of foods will lead to failure of GACC registration;

3. Incorrect application documents
Different types of GACC registrations for different food categories have different requirements for application materials,
The main application materials for GACC registrations include:

  • GACC registration application form
  • Business License for company
  • Production License for facility
  • Certificate of production management system
  • Recommendation letter from competent authority of country of origin (required for GACC-1-2, GACC-1-3 types)
  • Enterprise Information Form
  • Enterprise Commitment Statement
  • Processing flow chart
  • List of foods to be exported to China
  • List of Major raw materials & affiliated company
  • Product photos
  • Ingredient Formula
  • Chinese label
  • etc.
    These application documents need to meet the requirements of China's regulations and national standards; and some application materials also require Chinese versions.

    It is easy to make mistakes if you are not a professional in Chinese regulations;
    If all application documents are not submitted, or, if some of the application documents do not meet the requirements of GACC, it may lead to the failure of GACC registration;

    Moreover, if the applicant does not submit all the necessary application documents, the GACC will not start the review process, but the applicant thinks that he has completed the application and waits for the GACC review, it will resulting in both parties waiting in vain, wasting time;

  • ☼  I already have a GACC registration number for producer, why am I still unable to clear customs?

    At the end of 2021, many companies have obtained GACC registration numbers through batch applications from local authorities.

    However, many of these GACC registration numbers do not list the products to be exported to China by these enterprises, so many overseas enterprises still cannot export to China normally;

    These enterprises also need to apply for GACC product listing, list all products to be exported to China under this GACC registration number, then can clear China Customs normally;

    Since the applicants did not apply for GACC registration by themselves directly, there is no separate user ID assinged to them, so they cannot log in the GACC system to apply for GACC product listing;

    Therefore, overseas enterprises need to apply for a GACC user ID , before they can apply for product listing;

    ☼  I already have a GACC registration number for Exporter, can I export to China?

    In accordance with the provisions of GACC Decree 248 and 249, Imported food products must meet the following three necessary conditions, then can be legally imported into China.
    1. GACC registration of overseas exporters;
    2. GACC registration of overseas production enterprises;
    3. GACC listing of imported food;

    So, only apply the GACC registration of overseas exporter, it is not enough, the products still can't be imported into China;
    You must sure all the producers of your products to be exported to China, already have applied the GACC registration of overseas ​producer;

    The overseas food production enterprises Include:
    Agricultural farms, Food Processing plants, manufacturers, producers, processors, packers, re-packers, cold stores, storage operations,
    Fishing Vessels of Freezing or Transporting or Factory, etc

    Especially for some primary agricultural products,
    such as Edible grains, Nuts and seeds, Unroasted coffee/cocoa beans, Oilseeds, Plant spices, Vegetables, Fruits, etc.
    If the exporter purchases from individual farmers, then packs and stores it, and exports it to China,
    In that way,the exporters needs to assume the quality responsibility of these primary agricultural products,
    need to apply for the GACC registration of the production enterprise by Exporter‘s company itself;