Since the implementation of the General Administration of Customs of the People's Republic of China Decree No. 248 of 2021 "the Regulations of the People's Republic of China on the Registration and Administration of imported Food Overseas Production Enterprises" (hereinafter referred to as "Decree No. 248") for more than one year, Foodamte has successfully completed factory registration for more than one hundred overseas food manufacturers. based on the trust of Foodmate, many partners who also produce and operate pet food hope that we can help them with product registration and factory registration of imported pet food. This time, Foodmate will compare and analyze the similarities and differences between the registration of overseas manufacturers of imported food and imported pet food, for reference by industry peers.

I. Regulatory Requirements for Registration of Overseas Manufacturers of imported Food

In this regard, mainly refer to the requirements of Decree No. 248, and the relevant detailed requirements are summarized in the table below:

In general, imported food covers many categories, including 3 major categories: products of animal origin, products of plant origin and processed food that may contain ingredients of plant and animal origin. GACC will take different registration methods for enterprises according to the risk level of the products, and the corresponding registration materials are different. The registration for overseas manufacturers of imported foods is valid for five years, enterprises should apply for renewal of registration 3-6 months before the registration expires. In addition, the agency that registers overseas manufacturers of imported food in China is the import and Export Food Safety Bureau under GACC.

Ⅱ. Regulatory Requirements for Registration of Overseas Manufacturers of imported Pet Food

In China, pet food is a kind of feed product, and imported pet food should meet the requirements of the "Measures on Supervision and Administration of Inspection and Quarantine of import and Export Feed and Feed Additives". GACC implements a registration system for manufacture enterprises in countries or regions that are allowed to export feed (including pet food) to China, and imported feed (including pet food) should come from registered overseas manufacture enterprises. The relevant detailed requirements are summarized in the table below:

It can be seen from the above information that pet food is only a kind of animal-derived feed product, which needs to be recommended and registered by overseas competent authorities. The registration for overseas manufacturers of imported pet foods is valid for five years, and the enterprise should apply for renewal registration 6 months before the registration expires. In addition, the agency in charge of the registration of overseas manufacturers of imported food in China is the Department of Animal and Plant Quarantine under GACC.

Ⅲ. Similarities and Differences Between the Registration Requirements of Overseas Manufacturers of imported Food and imported Pet Food

We can analyze from the introduction of the first and second part of this article: the overseas manufacturer registration of imported pet food is similar to the manufacturer registration of imported food of animal origin, which belongs to the high-risk product category; GACC conducts access management for these products; Manufacturers of such high-risk products are recommended by the competent authority of the exporting country to GACC for registration, and the registration is valid for five years. The differences are summarized as follows:

(1) imported food and pet food have different registration authorities in China, and the registration materials for overseas enterprises are also different; imported food focuses on the dual responsibility system of overseas enterprises and their authorities, and effectively controls the food safety management at the source to ensure compliance with China's registration requirements; however, pet food manufacture registration focuses more on the safety requirements for product formula and whether it meets the requirements of the producing country, so as to meet China's registration requirements.

(2) Except for exemptions, imported pet food requires registration, but there are no such specific requirements for imported food of similar risk level of animal origin.

(3) The renewal of the registration of imported pet food overseas manufacturing enterprises need to apply six months in advance, and the registration of imported food overseas factory enterprises can be accepted 3-6 months in advance for application.

(4) So far, overseas manufactures of imported food are registered and approved in the CIFER system, but imported pet food is applied and approved through mail transmission and other methods, and there is no specific registration system.

Ⅳ. Brief Summary

From the perspective of registration material requirements, the initial material requirements for imported feed (including pet food) are relatively simple, but this is only for enterprises. In the actual recommended registration and approval process, the overseas competent authority will formulate corresponding feedback material requirements and even specific format requirements for such recommended registration work; enterprises may also be required to assist Overseas competent authorities reply to relevant questionnaires from GACC, all of which require enterprises to conduct targeted research. In this regard, Foodmate has accumulated corresponding registration experience and can provide practical assistance and guidance for the industry.