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Interpretation About Chinese “Administrative Measures on Supervision of Inspection & Quarantine of Imported & Exported Dairy Products” and Unqualified Imported Dairy Information Summary from 1st Quarter of 2017

As a leading dairy importing country, China shared about 30% of the total dairy trading quantity globally ( calculated as original milk), the main products including whole milk powder, skimmed milk powder and liquid milk. Besides, Chinese infant formula market is the most important in the world, it almost dominated by foreign brands.

On the other hand, there is still a huge consumption potential in Chinese dairy market. Comparing to developed countries, the Chinese average individual dairy consumption is 33kg per year, just half of Australia, 1/3 of global average consumption, and 1/8 of developed countries average consumption.

In order to establish a strong domestic dairy industry in China, Chinese government has implemented a series of measures these years from the management of raw milk to final products. While with the development of e-commerce and Chinese consumers always think the imported products standards for high quality, especially for infant formula products.

For the purpose of regulating domestic dairy market as well as protect local enterprises, The General Administration of Quality Supervision, Inspection and Quarantine of the People’s Republic of China published the “Administrative Measures on Supervision of Inspection & Quarantine of imported & Exported Dairy Products” on January 24, 2013, which came into effect from May 1, 2013. The Measures defines that it is by the AQSIQ to take charge of the inspection & quarantine of imported & exported dairy products.

The Measures specifies that the AQSIQ has implemented the registration system for overseas food manufactures who export dairy products to China, while it shall previously assess the food safety management system and food safety situation in the country or region where it locates. Dairy exporters or agents and related importers need to record to the AQSIQ. The list shall be published on the website of AQSIQ, which is consistent with the requirements of the “Regulations on Registration Administration of overseas manufacturers of imported food” introduced in the last issue.

The Measures also stipulates that imported dairy manufactures and importers shall ensure that the imported dairy products conform to the national food safety standards and related requirements of China possessed with Chinese labels and Chinese manuals in accordance with the relevant standards in China, and attached with the sanitary certificate issued by the competent government departments of the exporting country or region. Where it is necessary to handle the formalities for quarantine inspection and approval, it can only be imported after obtaining the “License for Animal and Plant Quarantine imported to the People’s Republic of China”. Overseas dairy production manufactures shall be able to provide the test report of the item specified in national food safety standards of China. importers need to publish the type, place of origin and brand of their imported dairy products.

On this basis, inspection and quarantine authorities will implement the inspection for imported dairy products. Where the imported dairy products are tested and quarantined unqualified in respect of safety, health and environmental protection projects, the inspection and quarantine authorities shall order the Parties to destroy or entrust the importers to handle the formalities of returning. Where the other projects are unqualified, they can only be sold or used after being re-inspected qualified by technical processing. In addition, the “Measures” also requires that if there is safety problems occurred in the imported dairy products, importers shall take the initiative to recall and report to the local inspection and quarantine authority. For the dairy products imported at the first time, importers or their agents shall provide the test report of projects listed in the corresponding national food safety standards when performing quarantine inspection to the customs inspection and quarantine authority. No matter whether there are importing records before the implementation of the Measures, a product departed from the outside shall be deemed as the initial importation from the first entry at one port since the implementation of the Measures.

According to the data of Query & analysis system regarding the sampling inspection of food independently researched and developed by Foodmate.net, a total of 963 batches of unqualified food products were notified at the first quarter of 2017 in China including 26 batches of unqualified milk and dairy products, of which there were 7 batches of liquid milk (GB 19644-2010 Milk Powder, GB 25190-2010 Sterilized Milk, GB 19645-2010 Pasteurized Milk, GB 25191-2010 Modified Milk), 2 batches of fermented milk(GB19302 National food safety standard fermented milk), 17 batches of cheese (GB5420 National food safety standard Cheese) and other dairy products. 26 batches of unqualified milk and dairy products mainly came from 7 countries and regions, including 7 batches from Italy, 4 batches from Taiwan in China, France, Italy and Netherland separately, 2 batches from the United States, and 1 batch from Lithuania. The main reasons for unconformity are due to exceeding shelf life of 10 batches, accounting for 38.46% of the total unqualified foods; the data problems (e.g. the certificate or qualified supporting documents are not provided as required, or the commodity does not match with the certificates, etc.) of 8 batches, accounting for 30.8% of the total unqualified foods; unqualified microbiology of 5 batches, accounting for 19.23% of the total unqualified foods (including coliforms of 3 batches, and yeast of 2 batches); unconformity on labeling of one batch(GB 28050-2011 National Food Safety Standard General Rules for Nutrition Labeling of Prepackaged Foods ,GB 7718-2011 National Food Safety Standard General Standard for the Labeling of Prepackaged Foods); and illegal use of sorbitol of one batch.

This shows that exceeding the shelf life and data problems constitute the main reasons for the unconformity of dairy products imported to China at the first quarter of 2017. Foodmate.net hereby warns the enterprises planning to export dairy products to China, one is to carefully study the requirements for import and export processes and data review of China, to avoid the unnecessary losses due to qualified products but incomplete data; the other is to timely follow-up the changes on the requirements of import process and documents of China, and shorten the import operation process as far as possible. If necessary, the third Party organization can be selected to provide regulation and technical support in this regard to avoid unnecessary losses due to the expiration of the product as a result of too long process.

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