INTERNATIONAL TRADE NEWS

NEW REQUIREMENTS FOR FOOD IMPORTS INTO CHINA

Rapid Consumer Market Growth With a population of roughly 1.4 billion, it is no surprise that the Chinese consumer market is the world’s largest. Like the EU and United States, the food and beverage sector has a very large piece of the consumer market share.

According to the China Chain Store & Franchise Association, China’s food and beverage (F&B) sector reached approximately $595 billion in 2019, a 7.8 percent increase over 2018. Predictions by Statista.com estimates a massive rate of growth at nearly $2 Billion by 2026.

Regulations Change Overview

China’s Registration Management System for Overseas Manufacturers of Imported Foods was established over two decades ago, in 1999. It is with little surprise that the General Administration of Customs of China (“GACC”) announced the Registration and Administration of Overseas Manufacturers of Imported Food (“GACC Decree 248”), which entered into force on 1 January 2022.

The decree was put into place due to the rapid growth of China’s imported food trade volume in the recent years, the increasing demand by consumers for imported food safety, and lastly due to the fact that the existing regulations can no longer meet the requirements of the current growth.

What Changes to Expect?

Upon implementation, GACC Decree 248 now requires all overseas food manufacturers, processors, and storage facilities of all food products (except food additives and food-related products) to register with the GACC.

In comparison with the current regulations, the GACC Decree 248 introduces several major changes.

Regulations Change Overview China’s Registration Management System for Overseas Manufacturers of Imported Foods was established over two decades ago, in 1999. It is with little surprise that the General Administration of Customs of China (“GACC”) announced the Registration and Administration of Overseas Manufacturers of Imported Food (“GACC Decree 248”), which entered into force on 1 January 2022. • The applicable scope is expanded to all food categories; previously regulations only applied to certain categories of foods.

• Extended registration period - the new version extends the registration period for manufacturers producing imported food overseas, from the current 4 years to 5 years.

• Details the specific steps necessary when undergoing an evaluation approach - document review, video inspection, and/or on-site inspection; contrasting to the old version which did not detail how to conduct the evaluation by the GACC.

• New requirements for the labelling of the Manufacturer Registration Number (MRN) on both the inner and the outer package of the product. The old version only required labelling of MRN on the outer package.

• Hold the overseas competent authority accountable for truthfulness, completeness, and legality of the submitted documents.

• Overseas manufacturers of imported food shall obtain registration from the

Essentially, the GACC Decree 248 is now imposed on all the imported edible products including foods, liquor, beverage, and traditional Chinese medicines (except food additives and food-related products). Any overseas manufacturer that wish to import foods into China, including manufacturers of production, processing, and storage must comply with these new regulations. • Letter of recommendation by the competent authority of the country (region) (The competent authority of the country refers to government agencies in charge of safety and sanitation regulation of food manufactures in the country).

How to Register?

Many questions quickly arise for international exporters of food such as, where to register? There are multiple systems to choose from, for instance, The The registration for overseas manufacturers of imported foods is valid for five years upon and from the official date of registration.

China Import Food Enterprise Registration System (CIFER system), which is GACC’s registration system, particularly for overseas food manufacturers exporting to China. Another system is the China International Trade Single Window, which is where all of the international trade-related businesses, unlimited to overseas manufacturers, needs to be inquired, registered, and completed for filing with the GACC.

What are the application materials required under the recommendation for registration?

• Letter of recommendation by the competent authority of the country (region) (The competent authority of the country refers to government agencies in charge of safety and sanitation regulation of food manufactures in the country).

• Documents certifying identification of the manufacturer, such as the business license issued by the competent authority of the country (region).

• Statement that the producer recommended by the competent authority of the country (region) conforms and complies with the requirements of these Regulations.

• Reports of examinations/inspections/ review conducted by the competent authority of the country (region) to the relevant manufacturers

• List of recommended manufacturers and the manufacturer’s applications for registration. Unless stated otherwise, the application materials for the manufacturer’s registration must be submitted in Chinese or English.