On January 3, 2025, the General Administration of Customs of the People's Republic of China (GACC) released the draft Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food for public comment, open from January 3 to February 19.
Compared to the current Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food (2021 Edition), the main changes in this draft for comment are as follows:
Introduction of Cooperation Agreements as a Registration Condition:
The previous regulations mainly emphasized that the food safety management system of the country (region) where the manufacturer is located must pass the GACC's equivalency assessment and review. The draft for comment introduces cooperation agreements signed by the GACC with overseas entities, including agreements on food safety cooperation and mutual recognition of Authorized Economic Operators(AEO). These agreements can now serve as conditions for system recognition, simplifying the registration process.
Establishment of a New Registration Method
Under the previous regulations, the registration process was relatively straightforward, primarily relying on self-registration from businesses or recommendations from the competent authorities. The draft for comment proposes establishing a new registration method that links manufacturer registration to the food safety system recognition from GACC.
For products requiring self-registration, if a foreign country or region's food safety system is recognized by GACC, enterprises would no longer need to apply individually through the online platform (and wait for GACC to review and assign a registration number). Instead, the list of recommended enterprises submitted by the competent authority is likely to be directly approved and granted registration numbers in China.
The previous regulations had relatively complex requirements for registration materials, and different types of food required different documents. The draft for comment provides clearer and simplified guidelines for the registration materials. Depending on the registration method, the required documents vary.
The draft for comment proposes reducing the list of food categories requiring an official recommendation letter for registration, from the original 18 to 11. This includes the removal of categories such as special dietary foods, health foods, seasonings, and edible oils. This adjustment reflects the GACC's principle of risk-based optimization of classification management. If implemented, this move will accelerate the market entry and circulation of foreign products in China, promote import trade, and stimulate market innovation.
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18 Categories (Current Regulation) |
11 Categories (Draft for Comment) |
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1. Meat and meat products 2. Casings 3. Aquatic products 4. Dairy products 5. Bird's nest and bird's nest products 6. Bee products 7. Eggs and egg products 8. Edible oils and fats 9. Filled pasta 10. Edible grains 11. Milled grain products and malt 12. Fresh and dehydrated vegetables and dried beans 13. Seasonings 14. Nuts and seeds 15. Dried fruits 16. Unroasted coffee beans and cocoa beans 17. Special dietary foods 18. Health foods |
1. Meat and meat products 2. Casings 3. Bird's nest and bird's nest products 4. Eggs and egg products 5. Filled pasta 6. Rice 7. Milled grain products and malt 8. Nuts and seeds 9. Dried fruits 10. Dairy products 11. Aquatic products |
The GACC determines and publishes the List of Foods Requiring an Official Recommendation Letter for Registration based on factors such as the source of raw materials, production processes, food safety historical data, consumer groups, and consumption methods, while aligning with international practices. The list is subject to dynamic adjustments by the GACC.
Products included in the list are primarily selected based on the following three factors:
1. High food safety risks associated with the product, with a significantly higher rate of non-compliance in imports compared to the average.
2. History of major food safety incidents within the product category, attracting significant public attention.
3. Alignment with internationally accepted practices.
The draft for comment specifies exemptions for overseas manufacturers in certain situations. Foods sent via mail, express delivery, cross-border e-commerce retail, or carried by travelers, as well as samples, gifts, promotional items, exhibition goods, aid products, and duty-free goods, are exempt from registration requirements. This provision offers clear guidance to relevant industries.
Enhanced Oversight Responsibilities for Overseas Authorities
The draft for comment emphasizes the supervisory duties of overseas competent authorities before, during, and after the registration process of food manufacturers. It requires these authorities to strictly fulfill their inspection, recommendation, and regulatory responsibilities, enhancing the safety and compliance of imported food.
Introduction of Random Inspections and Derecognition Mechanisms
The draft for comment grants the GACC the authority to conduct random inspections of companies on recommended registration lists. If non-compliance is detected, registration may be denied, and based on risk assessments, the GACC may also terminate the system recognition for the respective country or region. This mechanism helps ensure the quality and credibility of registered companies.
According to the 2024 China Import Development Report, China's food imports have experienced substantial growth, rising from $9.366 billion in 2001 to $217.127 billion in 2023—a remarkable 22-fold increase. During this period, China's share of the global food import market climbed from 2.06% in 2001 to 12.87% in 2023, underscoring its expanding role in international trade.
GACC data highlights the impact of registration regulations over the past three years, with more than 90,000 overseas food manufacturers from over 170 countries and regions successfully registered. Additionally, over 290 foreign competent authorities have used the system to recommend enterprises for registration in China, facilitating streamlined market entry for global food products.
Registration issues with the GACC are among the top reasons for customs rejections of imported food. In November 2024 alone, the GACC reported 507 batches of non-compliant imported food, 37 of which (7.2%) were rejected due to registration-related problems. To avoid potential losses, overseas food manufacturers and importers should ensure their qualifications and products meet all compliance standards before importation.
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http://www.customs.gov.cn/customs/302452/302329/zjz/6297231/index.html?VbY7rnwef3WG=1736216177792
