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Imported Food Compliance Requirements in China

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



Different categories of food products imported to China need to comply with different China's food safety regulations and the requirements of the relevant regulations of different government authorities;

if you don't complete all the relevant compliance procedures before shipment, even if your goods have arrived at the Chinese ports of entry, you may not be able to clear the customs, the goods will be returned or destroyed, resulting in huge losses.

If you are the first time to export food to China, it is best to find a professional import China compliance consulting company to be your CRA (Chinese Representative Agent) , comprehensive understanding of the various regulatory requirements of food imported into China,

Do not be greedy for cost savings, just consult your Chinese buyers, who are not aware of all the food imported into China's regulatory requirements, Blind Leading the Blind , which may lead to you do not complete all the compliance procedures and the goods cannot be cleared.

The most typical example:
Overseas food sellers are often told by their Chinese buyers to apply for GACC registration, but the buyers are not clear about what types of GACC registrations they need to apply for, or even what other Chinese government departments they need to apply for.

So most of the overseas food sellers just apply for the GACC-2-1 type of exporter registration, and think they have completed the GACC registration, and some of them just ship the goods directly, and as a result, when they arrive at the Chinese port, they are told by the Chinese Customs that they can't clear the goods because they didn't provide all the necessary GACC registration numbers.

Food imported into China, for GACC registration is just one of the requirements, For different food categories, in addition to GACC registration, may also need to be registered by other different governmental authorities, such as CIQ, MOA, AMR, MOFCOM, NMPA (CFDA) and so on;

Even for GACC registration:
Different company type and food categories need to apply for Different types of GACC registration, include:
1. GACC-1-1 type registration for overseas producers of Low risk food (18 digits number )
2. GACC-1-2 type registration for overseas producers of Medium risk food (18 digits number )
3. GACC-1-3 type registration for overseas producers of High risk food (18 digits number )
4. GACC-2-1 type General GACC registration for overseas exporters of imported food (11 digits number )
5. GACC-2-2 type Enterprises Whitelisting for Primary Agricultural and Livestock products (GACC white-list) (17 digits number )
6. GACC-5 type products listing for foods to be imported into China (13 digits HS-CIQ code )
    ( GACC-5-1 Low risk food,GACC-5-2 Medium risk food,GACC-5-3 High risk food, etc.)

If you do not apply for all the necessary GACC registrations, or apply for the wrong type of GACC registration, it may result in your shipment not being cleared;

Below is the "Check list for Food Products Export to China Compliance Requirements", you can initially check it, if there is no clear each other, and then consult your CRA to figure it out.


   ☼  Check list for Food Products Export to China Compliance Requirements

Step FAQs

China Regulations' Challenge

Solution
1
Are your Food category allowed to import into China from the country of origin?
.   A: YesB: No C: Needn'tD: Pending .
For some "high-risk" food Categories,need the Chinese government to sign relevant bilateral protocol with the country of origin in advance, before they can be allowed to import to china; such as agricultural products, meat, dairy products,Aquatic products,Feed, etc.

Consult your CRA
2
Does your company have GACC-2 exporter registration number (11 digits number) ?
.   A: YesB: No C: Needn'tD: Pending .
Before shipping to China, All imported food overseas exporter , need to apply GACC ( General Administration of Customs of China) registration in advance. In each Customs clearance process, need fill this GACC exporter registration number in all Customs documents;
">
Consult your CRA
 
3
Does your company have GACC manufacturer registration number (18 digits number) ?
.   A: YesB: No C: Needn'tD: Pending .
Before shipping to China, All imported food overseas manufacturers ,  need to apply GACC ( General Administration of Customs of China) registration in advance. In each Customs clearance process, need fill this GACC manufacturer registration number in all Customs documents;
">
Consult your CRA
 
4
If export primary plant or animal products, Does your company on the recommended whit-list for export China (17 digits number) ?
.   A: YesB: No C: Needn'tD: Pending .
If export primary plant or animal products, such as Edible grains (rice, wheat, soybeans, corn, etc.), Nuts and seeds, Unroasted coffee/cocoa beans, Oilseeds, Plant spices, Vegetables, Fruits, animal feed, Traditional Chinese Medicine materials, live animals and plants, etc., Also need apply fot Quarantine Registration List of Overseas Animals and Plants and Relevant Products (GACC-2-2 type whitelisting);
">
Consult your CRA
 
5
Does your product have GACC product listing number (13 digits HS-CIQ code) ?
.   A: YesB: No C: Needn'tD: Pending .
All imported food products are required to apply for GACC product listing, after get the 13-digit HS-CIQ code corresponding to its product be included in its manufacturer's registration number, then can be exported to China.
">
Consult your CRA
 
6
Do your products have Chinese labeling ?
.   A: YesB: No C: Needn'tD: Pending .
Most imported foods need to have chinese label except of some primary agricultural products. Each food category, have its specific Chinese label norm, include Content, format, labeling method, etc. the Chinese labeling samples must be submitted to CIQ for inspection before customs clearance ;
">
Consult your CRA
 
7
Do the formula ingredients of your product meet the requirements of China ?
.   A: YesB: No C: Needn'tD: Pending .
The formula ingredients of all imported foods must comply with the requirements of the relevant Chinese food safety regulations; Must not contain prohibited ingredients;The content of food additives must be within the allowable range; The formula ingredient evaluation report must be submitted to CIQ for review before customs clearance ;
">
Consult your CRA
 
8
Does the quality of your products meet China's requirements ?
.   A: YesB: No C: Needn'tD: Pending .
The quality indicators of all imported foods must meet the requirements of relevant Chinese food safety regulations and China national GB standards. CIQ will sampling test imported foods. The testing items mainly include physical and chemical indicators, heavy metals, microbiologicals, prohibited ingredients, etc..
">
Consult your CRA
 
9
Does your product require pre-market approval before importing?
.   A: YesB: No C: Needn'tD: Pending .
Some special food products, need to apply China's relevant government agencies pre-market approval, licensing or certification in advance before export to china ; Such as, Nutritional supplements, functional health foods, infant formula milk powder, pet foods, GMOs products, etc.;
">
Consult your CRA
 
10
Have you registered your trademark in China ?
.   A: YesB: No C: Needn'tD: Pending .
Usually the China customs will not check trademarks, but if your trademark has been registered in China and the registrant has applied for Customs intellectual property protection, your goods will not be cleared.
">
Consult your CRA

   ☼  Major China Administrative Agencies for Imported Food Products::

Abbreviation Agency Name Scope of supervision
GACC General Administration of Customs of China   All Overseas and domestic importers, exporters, manufacturers, customs agents related to import & export trade of China.
CIQ China entry-exit inspection and quarantine bureau   Inspection and quarantine for all import and export goods, GACC affiliated institutions.
NMPA National Medical Products Administration  Drugs, APIs, Pharmaceuticals excipients, pharmaceutical packaging materials, medical devices, diagnostic reagents, cosmetics, etc.
MOA Ministry of Agriculture of China   Primary agricultural products, GMO agricultural products, Animal feed, Pet food, etc.
CNCA Certification & Accreditation Administration of China   Overseas Manufacturer of dairy products, meat products, and aquatic products, China compulsory certification etc.
SAMR State Administration for Market Regulation of China   Functional health foods, nutritional supplements, infant formula milk powder, formula foods for special medical purposes, etc.
MOFCOM Ministry of Commerce of P.R.China  Import license, import quota, certificate of origin, etc.  
CFDA China Food and Drug Administration   The supervision function has been split into NMPA and SAMR
AQSIQ General Administration of Quality Supervision, Inspection & Quarantine The supervision function has been split into GACC and SAMR


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