IndraStra Global
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IndraStra Global

A Brief Note on China’s New Customs Regulations for Overseas Food Producers

The new food import regulations, which went into effect on January 1, 2022, include the Registration and Administration of Overseas Producers of Imported Food (Decree 248) and the Administrative Measures on Import and Export Food Safety (Decree 249). The measures, which were first announced in April 2021, cover a broad range of products from royal jelly to vegetable oils and infant food.

The GACC’s latest regulations have been introduced to ensure the quality and safety of imported food items. At present, the rules affect businesses across the supply chain, including food producers, processors, storage facilities, and more that fall within the following categories: 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 and health food.

For businesses that do not fall within the listed categories, businesses must seek approval from their national food safety authority (e.g. the Food & Drug Administration in the United States). The following rules are subject to change.

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.

In the past few years, China has done relatively better in enforcing food safety and quality standards for its food exports than it has for its domestic food market. A disparity between export quality and what is found in local markets is not uncommon in developing countries. But after several large-scale food safety incidents, domestic Chinese consumers are now paying close attention to the quality of their food and are no longer willing to accept such a disparity. But, these new import rules have faced some opposition. Diplomats from seven countries which also include Australia, Japan, Canada, and Switzerland, have asked to extend the grace period by another 18 months, saying businesses need time to adjust. Now the Chinese customs authorities have started offering online courses in a bid to help businesses make a smooth transition.

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