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Pre-Packaged Food Compliance in China

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Review of Food Formulation
Review, Translation, and Production of Food Labels
Comprehensive Analysis for Food Market Access
Consultation on Regulatory Requirements and Compliance Procedures for Food Imports

Definition of General Food in China

General food is not a specific term but rather a concept relative to special food. Special food includes health food, foods for special medical purposes, and infant formula food. Any food that falls outside the category of special food is considered general food. Examples of general food include rice, edible oil, vinegar, ham, milk, beverages, biscuits, canned food, ice cream, frozen dumplings, potato chips, candies, tea, alcohol, chocolate, honey, etc.

Criteria for Defining Imported General Food in China

It refers to food that is produced, packaged, and finally sold in packaging by overseas companies (including Hong Kong, Macau, and Taiwan) and is intended for import and sale within the territory of the People's Republic of China.

The food should possess the characteristics of general food and should not be in the form of capsules, sprays, drops, etc. It should also comply with the relevant national standards and/or industry standards for food types and the requirements of import food laws and regulations.

Regulatory Requirements for Imported General Food in China

Before import (qualification confirmation): Starting from January 1, 2022, overseas food production companies exporting food to China need to complete relevant registrations. It should be noted that the overseas production companies registering with Chinese customs include not only manufacturers but also processors, storage companies, etc.

Overseas exporters or agents exporting food to China and importers of food should also file records with Chinese customs. The list of registered importers and exporters is published by the General Administration of Customs and can be checked in the Importer and Exporter Filing System for Imported Food and Cosmetics. At the same time, relevant companies need to determine whether the food can be imported into China (compliance feasibility analysis: formulation, labeling).

During import (customs inspection): Customs will carry out quarantine inspections on imported food that requires entry quarantine in accordance with the law.

After import: Establish a traceability system and risk warning system for imported food, and take accurate actions for problematic products and companies.

In summary, imported food compliance means conducting a comprehensive "check-up" on food before import. It involves assessing whether the imported food meets the requirements of the Food Safety Law and related standards and regulations, and determining whether the food can enter China legally and be marketed.

"White List" for Specific Food Market Access

The General Administration of Customs assesses and reviews the food safety management systems and food safety conditions of foreign countries (regions) and establishes corresponding inspection and quarantine requirements based on the assessment and review results.

For seafood, dairy products, plant-based foods, meat products, bee products, sausage casings, and bird's nest products that have been reviewed and assessed as meeting China's regulatory requirements, the General Administration of Customs publicly announces their inclusion in an access list. This access list consists of countries or regions that meet the assessment and review requirements and have a history of traditional trade with China. The General Administration of Customs will adjust the list dynamically based on the assessment and review results. Therefore, seafood, dairy products, plant-based foods, meat products, bee products, sausage casings, and bird's nest products that are not included in the corresponding list should be considered as food not approved for import.

Checklist for Importing General Food Compliance and Market Access Documentation

NO.	Items	Main Content
1	Packaging	Foreign language design draft or images of minimum sales packaging (including inner packaging, if applicable) , along with their Chinese translations, must be complete and clear.
2	Formulation	For the outer packaging label, provide a complete list of ingredients and their respective proportions (as required by Chinese Customs). Include the English names of the ingredients and Certificates of Analysis (COA), ensuring that the total adds up to 100%.
3	Testing Report	Provide the COA from the country of origin and Chinese GB testing reports. Chinese GB testing should cover food quality, nutritional composition, and label claims (if applicable). Samples can be tested in China for GB testing.
4	Registration of Overseas Production Enterprises	The registration number must correspond to the product category.
5	Trademark Registration in China	The trademark registration certificate or acceptance notice must correspond to the product category.
6	Other Supporting Documents	Labeling claims such as patents, designated sponsors, vegetarian, gluten-free, etc.

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