China is strengthening oversight of imported food, particularly products entering through cross-border e-commerce channels. A recent enforcement inspection report, released during the 18th session of the Standing Committee of the National People's Congress, highlights regulatory gaps that could directly affect foreign companies' market access and long-term compliance stability.
While China has made notable progress in food safety governance over the past decade, including regulatory frameworks, standards, and enforcement capabilities, the report underscores that imported foods remain a key compliance challenge as authorities shift from "convenience-focused management" to more detailed, risk-based oversight.
The report identifies three major issues that currently hinder effective supervision:
Unclear testing requirements for imported foods
The Food Safety Law does not clearly specify whether inspections of imported foods should follow WTO-recognized conformity assessment procedures. This lack of clarity has made supervision by Chinese Customs reactive rather than proactive.
Need for scientific determination of testing scope
After an initial screening of appearance and packaging and subsequent sampling, it remains uncertain whether full-scope testing against China's food safety standards is always required. Current laws and regulations do not provide explicit guidance, leading to inconsistent enforcement.
Insufficient supervision of cross-border e-commerce foods
At present, cross-border retail imported foods are regulated under the rules for "personal use" goods. Consumers are therefore allowed to purchase products that may differ from China's food safety standards and bear any related risks themselves. As a result, certain imported products containing substances prohibited in China have entered the domestic market, posing potential food safety hazards.
To address the current regulatory gaps, the report calls for a clearer and more internationally aligned approach to imported food oversight:
Clarifying Customs' authority in conformity assessment
Customs should be empowered to adopt a risk-based inspection approach, selecting testing items more precisely to ensure efficient use of laboratory resources and improved regulatory outcomes.
Enhancing international alignment and trade facilitation
In addition to China's national food safety standards, accredited industry standards and Customs technical specifications could also be accepted for imported food testing. This would help China better align with global norms and create a more supportive business environment at ports.
Strengthening controls on cross-border e-commerce foods
New measures, including a negative list for high-risk imported products and clear recall obligations, would close loopholes that currently allow certain non-compliant items to enter the market through cross-border retail channels.
China's regulatory environment is moving toward standardized, risk-driven oversight of imported food. For overseas brands and cross-border e-commerce platforms, this translates into stricter compliance expectations from the very start of market entry. Proactive preparation, including early regulatory assessment, product reformulation when necessary, and stronger supply-chain documentation, will be essential to secure market access and ensure business continuity in China.
ZMUni Compliance Centre is here to help companies navigate China's regulatory landscape, from prepackaged food compliance and GACC registration to CBEC rules, marketing claims, health food registration, and new ingredient approvals.
Additionally, on November 27, we will be hosting a webinar on compliance for imported prepackaged food labels, where we will share practical guidance and the latest regulatory updates. Companies interested in attending are encouraged to register and join. For more information or personalized support, please contact info@zmuni.com.
