Understanding China’s New Custom Rules for Exporters

Does your business export food products to China? If so, you may need to meet two new regulations from the General Administration of Customs of China (GACC) that went into effect on January 1, 2022.

China is currently the world’s sixth-largest food importer. In recent years, the volume of food imported into the country has increased exponentially, largely due to the growing demand of an expanding middle class. According to the U.S. Department of Agriculture, China’s food imports were worth $89 billion in 2019.

The GACC’s new rules have been introduced in an effort by China to ensure the quality and safety of imported food items.

All businesses that export food products to China, no matter in what part of the supply chain, must comply with the new regulations. These include food manufacturers, processors and storage facilities.

The new regulations are:

• The Registration and Administration of Overseas Producers of Imported Food (Decree 248)
• The Administrative Measures on Import and Export Food Safety (Decree 249)

While specific details on the regulations are only now starting to fully emerge, NSF is well positioned to support businesses as they navigate their way through these requirements.

With offices located in Shanghai and Qingdao, NSF China offers local language expertise and a global network of food safety professionals experienced in the intricacies of food labeling.

The following information recaps the details available at the time of publication of this article. For the most up-to-date information, contact NSF.

The Registration and Administration of Overseas Producers of Imported Food (Decree 248) requires businesses across the food supply chain to complete registration for any products being exported into the country via the China Import Food Enterprises platform. Foods are divided into risk categories that determine which actions must be taken to meet the regulation. Once registered, products must include the assigned registration number (CHINA REG. NO.) in both their inner and their outer packaging.

The Administrative Measures on Import and Export Food Safety (Decree 249) replaces several regulations and covers a broad range of requirements, including the evaluation and review of foreign food safety management systems; overseas facilities registration; record filing by importers, exporters and commercial agents; quarantine and inspection; product labeling; and food safety risk, among others.

All companies must register their products online and receive an official registration number (CHINA REG NO.). Registration for low-risk-category products is valid for up to five years. Registration for high-risk-category products may require a more robust process, which could include additional registration information, on-site inspections and evidence of a suitable food quality management system in place (such as GMP or HACCP certification).

The food categories this decree applies to are as follows:

• Meat and meat products
• Sausage casings
• Aquatic products
• Dairy products
• Bird’s nest and bird’s nest products
• Bee products
• Eggs and egg products
• Edible fat and oil materials
• Stuffed pasta
• Edible grains
• Industrial products of grain flour and malt
• Fresh, preserved and dehydrated vegetables and dried beans
• Condiments
• Nuts and seeds
• Dried fruits
• Unbaked coffee beans and cacao beans
• Special dietary food
• Health food

A new online platform, the China Import Food Enterprises platform, has been launched for businesses to register their products. Currently, the platform is available in English and Chinese.

Once registration is granted, a registration number (CHINA REG NO.) will be issued to the product. This number must be displayed on both the inner and the outer packaging of the products being exported. This applies to bulk packaging as well as to individual packaging.

Need help navigating the platform? Contact NSF for support.

To help businesses meet the two regulations, NSF is now offering the following services:

• Step-by-step navigation through the China Import Food Enterprises platform and assistance with the obtainment of product registration numbers
• Labeling and packaging consulting services that support package design and labeling assurance
• Training on importing food safety-related laws and regulations

Businesses seeking assistance with meeting the new regulations can contact NSF for assistance in their home country or in China.

Managing regulatory change can be challenging, but the ability to stay ahead of and adapt to it is critical. In the last few years, shifts in regulations affecting food businesses have not let up. Recent events, such as Brexit, national elections, new trade agreements and new import/export rules, have all brought with them a wave of knock-on regulatory changes. Looking ahead, it appears unlikely that this pace will slow down.

NSF understands the need for clarity and confidence when it comes to changing rules and regulations. With a local presence in China and an international team of experts on hand, we’re here to help companies work through these new requirements and continue to export their products into the country.