China Issues New GACC Regulation on Registration of Overseas Food Manufacturers

Publication date：2025-10-15

On October 14, 2025, the General Administration of Customs of China(GACC) officially issued the Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food (Decree No. 280), which will take effect on June 1, 2026. Upon its implementation, Decree No. 248, released on April 12, 2021, will be repealed.

The new regulation was first published as a draft for public consultation on January 3, 2025, together with the Catalogue of Foods Requiring Official Recommendation for Registration (Draft for Comments), which has not yet been released.

Below is a brief comparison highlighting the key changes between Decree No. 248 and Decree No. 280:

Dimension	Decree No. 248	Decree No. 280	Key Changes & Analysis
Effective Date	January 1, 2022	June 1, 2026	Decree No. 280 will officially replace the previous regulation.
Registration Method	Fixed list of 18 food categories subject to official recommendation registration; others could apply directly.	Introduces a dynamic catalogue system—only foods listed in the Catalogue require official recommendation registration.	Shifts from a static list to risk-based dynamic management, offering greater flexibility.
Registration Conditions	Included a prerequisite that the exporting country's food safety system must have passed equivalence assessment.	Removes the equivalence assessment requirement.	Lowers institutional barriers and focuses more on individual enterprise compliance.
New Mechanism	/	Adds a "List-Based Registration" mechanism for countries with cooperation agreements with China.	Encourages mutual recognition and enhances trade facilitation.
Renewal of Registration	Enterprises must proactively apply for renewal 3–6 months before expiry.	Registration will be automatically renewed for another five years upon expiry, except in specific cases.	A major simplification measure that eases administrative burden on companies.
Regulatory Measures	Included provisions on cancellation, revocation, and suspension.	Provides more detailed rules, expands revocation scenarios, and clarifies public disclosure of registered lists.	Stronger transparency and more precise supervision.
Scope of Application	Did not specify cross-border e-commerce.	Explicitly states that cross-border e-commerce will be governed under separate regulations.	Reflects adaptation to emerging trade models.