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DHA Algal Oil, Vitamin D Beverages, and Other Imported Food Products Rejected by China Customs: Analysis of Non-compliant Food Imports in October 2024
Publication date:2024-12-19

 

On November 22, 2024, China's General Administration of Customs (GACC) released its list of non-compliant imported foods for October 2024. A total of 198 batches from 28 countries/regions were rejected, representing a notable decrease of 58.0% compared to the previous month and a 19.5% decrease compared to the same period last year. This significant decline marks the first time in 2024 that the number has fallen below the same period in previous years.

 

The majority of non-compliant imports came from the U.S. (14.6%, mainly beer), Canada ranked second (10.6%, all sports nutrition products), Japan (9.6%, primarily beer), and Taiwan, China (7.4%, mostly snacks). Key reasons for import rejections included:

 

- Unqualified labeling

- Discrepancy between cargo and certificates

- Non-compliance with national food standards

- Issues regarding overseas manufacturer registration

- Detection of animal diseases

 

ZMUni Compliance Centre has highlighted some notable cases from the October import alert for your reference:

  

1. "Unapproved Plant-based Ingredients" in DHA Algal Oil form Australia

 

According to China's former Ministry of Health Announcement No. 3 (2010), approved microbial strains for producing DHA algal oil include Schizochytrium sp., Ulkenia amoeboida, and Crypthecodinium cohnii. The Announcement also specify production processes, recommended intake, and quality standards.

 

It's important to note that DHA algal oil produced using strains other than the approved ones mentioned above must undergo registration as a new food ingredient and receive approval before entering the market.

 

  • Compliance Tip: Companies must ensure the raw material sources and production processes of approved new food ingredients meet regulatory requirements to avoid border rejections.

 

2. L-Arginine in Solid Beverages from Australia Not Meeting China's National Food Safety Standards

 

L-Arginine is listed as a permitted synthetic flavoring in Appendix B of GB 2760-2014 National Food Safety Standard Standard for Uses of Food Additives under Table B.3, Permitted Synthetic Food Flavorings. However, it must comply with the principles for food flavoring use and be incorporated into foods as part of a flavor preparation. The maximum allowable usage is 250 mg/kg.

 

When used as an amino acid source, L-Arginine (L-2-amino-5-guanidinopentanoic acid) can be used in special medical purpose infant formula (13.01.03) and special medical purpose formula foods (excluding certain types in 13.01 and 13.03) according to the Announcement on the Management of Amino Acids in Foods for Special Dietary Uses (2023 No. 11) by the National Health Commission(NHC) and the State Administration for Market Regulation(SAMR).  

 

It must be produced from starch or sugars through fermentation and comply with relevant quality standards. The usage amount should be determined in accordance with the GB 25596 National Food Safety Standard General Rules of Infant Formula Foods for Special Medical Use and GB 29922 National Food Safety Standard General Rules for Foods for Special Medical Purposes, among other standards.

 

  • Compliance Tip: When exporting food products containing L-Arginine or similar ingredients to China, international companies should carefully verify their intended use and dosage to ensure compliance and avoid export denials.

 

3. Vitamin D (Cholecalciferol) in Beverages form New Zealand Not Meeting China's National Food Safety Standards

 

Under GB 14880-2012 National Food Safety Standard Standard for the Use of Nutritional Fortification Substances in Foods, Cholecalciferol (Vitamin D3) can be added to specific foods, provided it stays within the permitted usage limits.

 

Food Name

Usage Amount

Modified Milk Ingredients

10-40 μg/kg

Modified Milk Powder (excluding children and pregnant women)

63-125 μg/kg

Modified Milk Powder (for children only)

20-112 μg/kg

Modified Milk Powder (for pregnant women only)

23-112 μg/kg

Margarine and Similar Products

125-156 μg/kg

Margarine and Similar Products

10-20 μg/kg

Soybean Powder, Soy Milk Powder

15-60 μg/kg

Soy Milk

3-15 μg/kg

Lotus Root Powder

50-100 μg/kg

Instant Grains, including Rolled Oats (flakes)

12.5-37.5 μg/kg

Biscuits

16.7-33.3 μg/kg

Other Baked Goods

10-70 μg/kg

Fruit and Vegetable Juices (including fermented products, etc.)

2-10 μg/kg

Dairy Beverages

10-40 μg/kg

Flavored Beverages

2-10 μg/kg

Solid Beverages

10-20 μg/kg

Jelly

10-40 μg/kg

Puffed Foods

10-60 μg/kg

Flavored Fermented Dairy

10- 40 μg/kg

Cheese and Processed Cheese (processed cheese only)

63- 125 μg/kg

Other Dairy Products (only milk tablets)

63- 125 μg/kg

Plant Protein Beverages

3 -15 μg/kg

 

Vitamin D3 can also be used as a nutrient in foods for special dietary purposes, but its content must adhere to the relevant product standards.

 

  • Compliance Tip: Companies must ensure that the Vitamin D content in their products aligns with the maximum usage limits for the intended food category to prevent rejection due to overuse or misuse.

 

 

ZMUni Reminder:

 

In 2023, the General Administration of Customs reported 2,358 batches of food imports failing to meet entry requirements. By October 2024, this number had already climbed to 3,233 batches, marking a substantial increase over last year.

 

Food safety is critical. To minimize entry rejections, businesses should reinforce compliance checks prior to import, ensure customs documentation accuracy, and strengthen supplier quality management. Staying updated on the latest food regulations and standards, along with consulting on compliance when needed, can help secure smooth market entry.

 

ZMUni Compliance Centre brings extensive expertise in pre-packaged food compliance and import clearance. For inquiries or support to ensure the efficient and successful entry of your products into China and other markets, please contact us at info@zmuni.com.