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On 13 April 2021, the General Administration of Customs, P.R.China (GACC) issued the “Administration Measures on the Registration of Overseas Manufacturers of Imported Food” (hereinafter called as the “New Regulation”), which will come into force as from 1 January 2022. Comparing to the current regulation, 3 significant changes shall be taken seriously by the overseas manufacturers.

1. Registration scope is expanded to all imported foods

Current Regulation	I. Overseas manufacturers whose food categories are listed in the Registration List shall obtain the overseas manufacturer registration before exporting the products to China. II. Currently, only the overseas manufacturers of meat product, aquatic products, dairy products (including infant formula) and edible bird’s nest need to apply for registration.
New Regulation	Overseas manufacturers of imported food shall obtain the registration approval from GACC. Note: The overseas manufacturers of imported food additives and food-related products are not required to register the factories.

Provisions relating the Registration List were removed in the New Regulation, and the registration scope is expanded to all imported food categories, which means that, in addition to the current food categories of meat product, aquatic products, dairy products (including infant formula) and edible bird’s nest, overseas manufacturers of all else food categories (such as health food, food for special medical purposes, and even beverage, candy, etc.) need to carry out the registration as from 2022.

2. Different food categories, different registration methods

According to different food categories, there will be two ways to register factories. One is “be recommended to GACC by the exporting country’s competent authority (hereinafter called as local authority)”, the other one is “applied by the manufacturer himself or his entrusted agent”.

Registration methods	Scope of food categories
Recommended by local authority	Meat and meat products, casings, aquatic products, dairy products, bird's nest and bird's nest products, bee products, eggs and egg products, edible fats and oils, stuffed pasta, edible grains, grain milling industrial products and malt, fresh and dehydrated vegetables and dried beans, seasonings, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, special dietary foods, health foods. Currently, special dietary foods in China include infant formula foods, infant complementary foods, foods for special medical purpose (FSMP), nutrition supplementary foods, sports nutrition foods, nutrition supplementary food for pregnant women and wet nurse.
Applied by the manufacturer himself or his entrusted agent	Food categories other than those mentioned above.

It can be found that food categories whose manufacturers are required to be recommended to registration by local authority, are mostly those with higher levels in food safety risks or in consumer sensitivity. While the manufacturers producing general food with lower risks (e.g., beverage, candy, chocolate) can apply the registration by themselves or their entrusted agents.

In addition, it should be noted that:

1) If the risk analysis or evidence shows that the risk of a certain kind of food has changed, GACC can adjust the application method and application materials of the corresponding manufacturers.

2) If the relevant countries (regions) and China have another agreement on the registration method and application materials, it shall be implemented according to the agreement.

3. Adjust application materials for different registration methods

The application materials are different for the above two registration methods. Details are as follows.

Registration methods	Application materials
Recommended by local authority	1) Recommendation letter of the local authority; 2) List of manufacturers and their application forms; 3) Identification documents of the manufacturer, such as business license issued by the local authority; 4) Statements of the manufacturers promising to meet the requirements of this regulation; 5) The review reports of the local authority on the examination of relevant manufacturers; 6) If necessary, the food safety, hygiene and protection system documents will be required by GACC, e.g., the floor plan of the factory, workshop, and cold storage, the process flow chart, etc.
Applied by the manufacturer himself or his entrusted agent	1) Registration application form; 2) Identification documents of the manufacturer, such as business license issued by the local authority; 3) A statement that the manufacturer promises to meet the requirements of this regulation.

At present, the detailed requirements of the materials have not been clear yet, while it is speculated that, GACC would issue corresponding supplementary documents or update the online system of China Import Food Enterprise Registration in accordance with the requirements of the New Regulation in the near future, so as to help the applicant understand the specific material requirements.

In addition, there are other obvious changes of the New Regulation, which are:

More review and verification methods: After receiving the registration application, GACC will organize the review on the manufacturer in more flexible ways like “written inspection”, “remote video casual inspection”, “on-site inspection” and combinations thereof.

Extend the validity of registration certificate: The validity of registration certificate of the new regulation will be changed into 5 years from 4 years in the current version.

Summary

The most significant change in the new regulation is that beside dairy products (including infant formula), meat products, aquatic products, and edible bird’s nest, all the other food categories including health food, FSMP, infant food, wines, prepackaged food like beverages, candy, chocolates, etc. shall also register the manufacturer at GACC before entering Chinese market as from 2022.

In order to ensure the normal import of all imported food during the registration application period, CIRS speculates that GACC would issue an announcement offering the manufacturers a transition period for the registration.

CIRS Group is a global product compliance consulting firm. With its headquarters based in Hangzhou of China and subsidiaries or laboratories located in Ireland, the United States, the United Kingdom, Korea, Beijing, Nanjing, and Ningbo, CIRS Food Business Division utilizes its Localization advantages of domestic offices and network of overseas subsidiaries to provide more professional and timely Chinese food regulation compliance services for oversea food companies entering China, including supporting of oversea manufacturer registration service.

If you have any question regarding the registration of oversea food manufacturer, please do not hesitate to contact at service@cirs-group.com

Official Link:

Notice of “Administration Measures on the Registration of Overseas Manufacturers of Imported Food”

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All Overseas Food Manufacturers shall Register the Factory at GACC before Entering China Market as from 2022