Interpretation | Administrative Regulations on the Registration of Overseas Manufacturers of Imported Food

On April 13, 2021, the General Administration of Customs of China (GACC) issued the "Administrative Regulations on the Registration of Overseas Manufacturers of imported Food" (hereinafter referred to as the “Regulations”), which will be officially implemented on January 1, 2022. Foodmate compares and interprets the new version of the regulations with the current versionyou’re your reference.

1. Expand the scope of registration

According to different food classifications, the registration methods are divided into registration recommended by the competent authority of the country (region) where the overseas production company is located and registration application by the company.

The food categories that need to be recommended and registered by the competent authority of overseas manufacturers are: 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 cereals , grain milling industry 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.

Overseas food manufacturers other than the foods listed above may apply for registration to GACC by themselves or by entrusting their agents.

2. Scientifically adjust the registration application materials

The regulations adjusted the application materials for overseas factory registration. After completing the evaluation and review of the food safety management system of the country (region) where the overseas production company is located, it is no longer required to provide dossiers including animal and plant epidemics, veterinary hygiene, public health, food production enterprise registration and management, hygiene requirements, and the establishment and personnel situation of the competent authority of the country (region). Instead, the application materials have added the requirements for the recommendation letter of the competent authority of the country (region) and the corporate identity certification document, emphasizing that overseas manufacturers need to have legal qualifications in the country (region) where they are located.

3. Innovate the registration review method

The regulations clarify that the registration review method will be carried out through written inspections, video inspections, on-site inspections and other forms and combinations thereof.

4. Clarify management of registration numbers

It is clarified that overseas manufacturers will be given a registration number in China after obtaining registration. When exporting food to China, overseas manufacturers may mark the food packaging with the registration number in China or the registration number approved by the competent authority of the country (region) where they are located. In addition, companies should note that, unlike the current regulatory requirements, in addition to marking the registration number on the outer packaging of the food, the inner packaging of the food also needs to be marked.

5. Adjust the validity period of registration of overseas manufacturers

The regulations extends the validity period of the registration of imported food overseas manufacturers from 4 years to 5 years, which is same as the "production license" for food exported to China from overseas factories.

6. Clarify changes and renewal application materials, and relax the time for renewal applications

Although the current administrative regulations mention the situation of registration change and renewal, it does not specify the application materials that need to be submitted. This time, the new version of the management regulations clarifies the details of the materials that need to be submitted.

In addition, the new version of the management regulations clarifies that if the production site is relocated, the legal representative is changed, or the registration number granted by the country (region) is changed, it does not belong to the scope of change registration and needs to be re-registered.

GACC has relaxed the time for initiating the renewal of registration, from 1 year before the expiration of the registration validity period to 3 to 6 months before the expiration of the validity period.

7. Reducing the scope of competent authorities for overseas manufacturers

The new version of the management regulations clarifies that the competent authority is the official department responsible for the safety and health supervision of food manufacturers in the country (region) where the foreign production enterprise is located, that is, the official authorized institutions and industry organizations are no longer recognized as competent authorities.

8. Deleted relevant regulations for Hong Kong, Macau and Taiwan

According to current management regulations, Hong Kong, Macao and Taiwan need to register overseas factories in accordance with the regulations before exporting food to China. The relevant content has been deleted in the new version of the management regulations. In the future, there may be changes in the registration and management of overseas factories in Hong Kong, Macao and Taiwan.

Foodmate plan to organize an online seminar about the interpretation of new regulations on April 26. We will invite experts working for GACC to discuss the trends of import and export food in China and give food manufacturers some suggestions. Details of the seminar are showed in the picture.


Please note: Original English article of Business Division of Food Safety and Regulatory Compliance of Global Foodmate, please indicate the source from the Global Foodmate if reprint.

Business Division of Food Safety and Regulatory Compliance of Global Foodmate provides food standards & regulations research, labelling compliance consulting/Chinese label design, industry public opinion monitoring and analysis, registration services (of Infant formula, FSMP, Health food, Novel Food Ingredients, Novel Food Additives, New Varieties of Food-Related Products and Overseas manufacturers of imported food) and other comprehensive food safety solutions for domestic and overseas enterprises and institutions in food industry. 

Please feel free to contact us: +86 10 68869850, E-mail: global_info@foodmate.net

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