According to the Food Safety Law of the People's Republic of China, imported food, food additives and food-related products shall meet the national food safety standards; imported foods that have no food safety national standards, from overseas exporters, overseas production enterprises, or their entrusted importers to submit relevant national (regional) standards or international standards implemented by the Health Administration of the State Council, and the relevant standards of health administrative departments of the State Council The review is considered to meet the requirements of food safety, and it is determined to temporarily apply, and the corresponding food safety national standards are set in time.

Therefore, foreign exporters from China export food, food additives, and food-related products need to understand China's food safety national standard system, but also understand the management requirements of China's food for imports without national standards.

I. Introduction of China's national food safety standard system

China Food Safety National Standards include general standards, product standards, production and operation standards, and testing methods standards. For imported food, food additives and food related products, food safety general standards, food safety product standards are particularly important.
Food safety general standards include fungal toxins, pollutants, farm drugs, limitations of pathogenic bacteria, food additives, food nutrient reinforcing agents, and label identification class standards, a total of 12, see the table below.


Food safety product standards are based on food, food additives, food related products, according to the product category, formulate the requirements for the limit or use of various health factors or labeling requirements. Food safety product standards mainly include food product standards, special dietary food standards, food additive quality specifications and related standards, food nutritional reinforcing agent quality specifications and related standards, food-related product standards. For example, GB 5420-2021 "Food Safety National Standard Cheese", GB 10765-2021 "Food Safety National Standard Infant Formula", GB 1886.1-2021 "Food Safety National Standard Food Additives Sodium Carbonate".

Product standards are consistent with general standards. If there are provisions on a certain product in the general standards, the food safety product standards of the product shall be directly referenced; for example, the relevant general standards for pollutants, pathogenic bacteria and food additives shall be directly referenced. Product standards may be formulated for specific pollution factors and quality indicators related to food safety that are not specified in the general standards. Both product standards and general standards are considered to have national food safety standards.

Ⅱ. China's requirements for the management of imported food without national food safety standards

imported food without national standards refers to food that is produced and marketed abroad and that China has not formulated and published corresponding national food safety standards. It does not include foods already covered by general standards or product standards in national food safety standards, foods announced or approved by relevant departments of The State Council, premixed foods mixed with various raw materials of existing food safety standards, and other circumstances that are imported and have no national food safety standards, etc.

To apply for importing non-national standard food, the overseas exporter, the overseas production enterprise or the importer entrusted by it (hereinafter referred to as the applicant) shall submit the application form and application materials to the National Food Safety Risk Assessment Center. Materials include application form for technical review of relevant standards for importing non-national standard food, certification materials for overseas permitted production and operation of imported non-national standard food, etc.

Procedures for reviewing relevant standards of imported non-national standard food: The applicant shall submit the application by logging in to the "Food Safety National Standard Proposal Solicitation and import Non - NATIonAL Standard Food Related Standards Technical Review Application System" (website: https://bzlx.cfsa.net.cn, hereinafter referred to as the system)→The food evaluation center will conduct formal review, preliminary review, solicit opinions and technical review of the materials, and give review conclusions→Inform the applicant online through the system.