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What is CRA? What kind service does CRA provide ?

Tags: | GACC | Food | Food | 海关总署 | 食品 | 食品 |




   ☼  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 necessary to appoint a CRA company for GACC registration?

According to the “GACC Announcement No. 105 of 2024”, starting from September 5, 2024, overseas exporters applying for GACC registration can not submit the application to GACC directly, but have to appoint a > CRA ( Chinese Representative Agency ) to act on their behalf;

The CRA must be a local company in mainland China and must be authorized by GACC to use the China e-Port Key (A special net security equipment provided by GACC ) in order to log in the latest Administrative Counterpart Management Subsystem of China Customs (Version 3.0 ) for GACC registration.

根据“海关总署公告2024年第105号公告”的规定,从2024年9月5日起,海外出口商申请GACC注册,不能直接向GACC提交申请,必须委托一家CRA公司代理办理;

CRA公司须是中国大陆的本地公司,并且需要得到GACC的授权,使用GACC提供的中国电子口岸密钥(海关专门的网络安全设备),才能登录最新的海关行政相对人统一管理子系统(3.0版)办理GACC注册。

   ☼  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.; 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;

   ☼  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.


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