Purpose
The purpose of this guide is to provide general guidance to local food manufacturers who wish to apply for “Advance Release Permission for the export of their food products to the Mainland” (“Advance Release Permission”) under Advance Release Arrangement to ensure compliance with the requirements of the “Cooperation Agreement on the Supervision of Safety and Facilitation of Customs Clearance of Food Products Manufactured in Hong Kong Exported to the Mainland”. During customs clearance at the ports on the Mainland, qualified food products with satisfactory on-site inspection of the Mainland Customs that are still required to go through sampling and testing can be released upon completion of sampling without waiting for the results.
Applicable Food Categories
At present, the Advance Release Arrangement covers three major categories of food as follows:
- beverages and frozen drinks (excluding alcoholic and milk beverages);
- biscuits, pastries and bread; and
- candies and chocolates (including chocolate, cocoa butter substitute chocolate and their products).
Food classification is based on Chinese HS code and Inspection and Quarantine (CIQ) code. Please refer to Table 1 [Chinese version only] for the codes of the above three food categories.
Implementation Ports on the Mainland
Advance Release Arrangement is in place at the ports under Shenzhen Customs, Gongbei Customs and Huangpu Customs.
Application Criteria
A food manufacturer must comply with the following requirements:-
- A food manufacturer must be a holder of a valid food factory licence issued by this Department;
- Food products must be manufactured in the food factory stated in the aforesaid food factory licence;
- A food safety management system with relevant certification (that is, ISO 22000 or HACCP certification) must be in place in the food factory concerned; and
- The food products concerned must comply with the national standards and laws of Mainland China.
Requirements for Food Testing
Food Manufacturers have to submit test certificate with relevant test report within the last six months issued by a recognised third-party institute certifying that the food products comply with the national standards of the People’s Republic of China. Food manufacturers may make reference to the Hong Kong Laboratory Accreditation Scheme (HOKLAS) for the organisations and laboratories accredited for food testing services. Food manufacturers may also consider other organisations and laboratories which are the Mutual Recognition Arrangment Partners of HOKLAS, such as the “China National Accreditation Service for Conformity Assessment” (CNAS).
In general, the testing parameters for the aforesaid 3 food categories include quality, food additives, pesticides, contaminants, microorganisms and biotoxin, etc (Table 2 [Chinese version only]). The food tests required may also depend on food ingredients and their nature. This Department may request food manufacturers to conduct additional tests for compliance with relevant standards. The food safety national standards for relevant food products are listed in Table 3 [Chinese version only]. Food manufacturers may check the website of the National Health Committee of the People’s Republic of China for detailed information of the national standards. Your attention is drawn to the announcements in the latest version of the national standards which may be updated by the competent authority on the Mainland from time to time.
Submission of Applications
- Online Application
Traders who have opened user accounts on the Food Trader Portal (FTP) may submit applications for “Advance Release Permission” with the required information on the FTP website (www.ftp.cfs.gov.hk).
- Paper Mode Application
Food manufacturer has to submit a completed application form (FEHB 346) together with the required documents to the Centre for Food Safety of the Food and Environmental Hygiene Department at Room 3508, 35/F, Hopewell Centre, 183 Queen’s Road East, Hong Kong by post or email (fsc@fehd.gov.hk).
Application Fee
After the application passes the preliminary assessment, the food manufacturer should pay an application fee of HK$8,305. The application fee is non-refundable regardless of whether the application is approved or not.
Application Processing Time
If all the required information and documents provided by the applicant have met the application requirements and the application fee has been paid, the “Advance Release Permission” may be issued within 21 working days.
Validity of “Advance Release Permission”
After the “Advance Release Permission” has been granted, if the applicant does not alter relevant food product information and the supporting documents including the food factory licence and the certificate of food safety management system remain valid, the permission will remain valid.
Notes for Attention
(I) The “Advance Release Permission” is a preliminary qualification review process. Applicants who have been issued with the Permission must ensure that each consignment of the food products exported to the Mainland through the Advance Release Arrangement:
- is accompanied by a “Health Certificate for Foods of Animal Origin” or “Food Inspection Certificate” issued by this Department [to be applied separately with this Department];
- is accompanied by a “Certificate of Hong Kong Origin -CEPA” [to be applied separately with the Trade and Industry Department (TID) or Government approved certification Organisation]; and
- complies with relevant legislation and regulations of Mainland China including provision of a simplified Chinese label on the smallest sales pack.
(II) Food manufacturers should note the GACC Decree No. 248 《Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food》 requires all overseas manufacturers of production (including food factories in Hong Kong) that export foods to Mainland China to register with the GACC.
(III) Whether the Advance Release Arrangement applies to individual consignments of food products during customs clearance at the ports on the Mainland is the decision of the GACC.
Enquiries
For enquiries, please contact our staff (Tel: 3108 2754) during office hours. Enquiries may also be sent to this Department by fax on 3108 2719 or email to fsc@fehd.gov.hk.
Centre for Food Safety
Food and Environmental Hygiene Department