China imposes new registration requirements on all foreign food companies

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The Regulations on the Registration and Administration of Overseas Producers of Imported Food will enter into force on January 1, 2022

Chinese government imposes new regulations that will take effect on January 1, 2022 and will replace the existing laws regulating imported food and overseas facility registration.

These regulations are as follows:

  • Regulations on the Registration and Administration of Overseas Producers of Imported Food (Decree 248) [1]
  • Administrative Measures on Import and Export Food Safety (Degree 249) [2]

 

New Registration Requirements

Once implemented, Decree 248 would expand the scope of overseas facilities subject to a registration requirement to include all food manufacturers, processors, and storage facilities.

Under the legislation currently in force, only overseas manufacturers of meat products, acquatic products, dairy products (including infant formula) and – though probably not of interest for Italian companies – edible bird’s nests, are required to apply for registration. The new Regulation, whereas, extends the obligation of Customs registration to all those who are intended to export food in China, regardless of the relevant food category.

The new facility registration requirements differ based on the specific types of food products manufactured:

  • Group #1: 18 categories of food subject to the registration recommended by the competent authority of the home country, including: meat and meat products; casing; aquatic products; dairy products; bird’s nest and bird’s nest products; bee products; eggs and egg products; edible fat and oil; stuffed pasta; edible grains; grain milling industrial products and malt; fresh and dehydrated vegetables and dried beans; seasonings; nuts and seeds; dried fruits; unroasted coffee beans and cocoa beans; special dietary foods; and health food.
  • Group #2: Other foods not covered by the above 18 categories.

Facilities that manufacture products covered by Group #1 need to first obtain recommendation by the competent authority (defined as the government agency in charge of food safety) of the local jurisdiction for facility registration.  There are also detailed requirements for the registration dossier including, when requested, food safety documents, facility design, and manufacturing process flow chart. Facilities that manufacture products covered by Group #2 can directly apply for facility registration with less stringent document requirements.

Labelling

Once implemented, Decree 249 will provide new enforcement tools for GACC to suspend or prohibit food importation into China when violation with applicable Chinese laws and regulations are identified.

The new Administrative Measures provide for provisions in matters of labelling of imported food products by introducing more detailed requirement for products as frozen meat and acquatic products. Both categories are required to report the label in Chinese and English or Chinese and the mother tongue of the exporting country, indicating all the necessary information required.
Food categories subject to a new labelling procedure imposed by the Chinese Government have been expanded.
At present, the label printed on the packaging (and not the Chinese label affixed in sticker format on the original packaging) is required only to products as infant formula milk powder. Starting from the 1 January 2022, pursuant the new Administrative Measures, this requirement will be extended to all special dietary products, including infant formula foods, infant complementary foods, foods for special medical purposes, nutrition supplementary foods, sport nutrition and nutrition supplementary foods for pregnant women.
The above mentioned categories will be, therefore, required to print the label on the packaging and not affixing it in sticker format.

Files

Regulations of the People’s Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food

 

China represents one of our main markets. We can count on the support of our local trusted agents and our Chinese speaking staff.

Contact your Italian freight forwarder for any inquiry and information request!

     

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