Decree No. 248 《Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food》and Decree No. 249 《The Measures of the People's Republic of China for the Administration of Import and Export Food Safety》of the General Administration of Customs of the People's Republic of China

New Requirements on Export of Foods to the Mainland

The General Administration of Customs of the People's Republic of China (hereafter referred to as "the GACC") Decree No. 248 《Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food》 (hereafter referred to as "Registration Regulations") and GACC Decree No. 249 《The Measures of the People's Republic of China for the Administration of Import and Export Food Safety》 (hereafter referred to as "Administrative Measures") took effect on 1 January 2022. All overseas manufacturers of production, processing and storage (including food factories and processing plants in Hong Kong) that export foods to Mainland China are required to register with the GACC.

For the following 18 categories of food, namely meat and meat products, casings, aquatic products, dairy products, bird's nests and bird's nest products, bee products, eggs and egg products, edible oils and fats and oilseeds, stuffed pastry products, edible grains, milled grain industry products and malt, fresh and dehydrated vegetables and dried beans, condiments, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, foods for special dietary purposes and functional foods, the overseas manufacturers to be recommended for registration shall be examined and inspected by the competent authorities of their countries/regions.  After confirming that the overseas manufacturers conform with the registration requirements, the authorities can make the recommendation by providing necessary application materials and reports to the GACC.  The GACC has different registration requirements for manufacturers of different foods.  The factors of consideration include sources of food ingredients, food production and processing technologies, previous food safety records, consumer groups, modes of consumption, etc.  As for overseas manufacturers of foods other than the 18 categories, they can visit the China International Trade Single Window and use the simplified "self-application by enterprise" mode to apply for registration with the GACC.

Registration Procedures

The GACC has published on its official website a guide to handling government affairs service matters related to "Registration of Overseas Manufacturers of Imported Foods" to explain the registration process to enterprises concerned.  The information for application, covering food classifications and HS codes, the requirements for registration of the 18 categories of food and a compliance checklist, have also been uploaded onto the System of China Import Food Enterprise Registration of the China International Trade Single Window.  Traders may find the detailed information after login/registration on the website.  This Department has been recognised by the GACC as one of the competent authorities in Hong Kong to make recommendation on manufacturer registration of the 18 categories of food under its purview.  Traders may refer to the Application Guide for Recommendation on Food Manufacturer Registration for details.

Overseas manufacturers of foods outside of the 18 food categories can use the China Import Food Enterprises Registration system via the China International Trade Single Window to apply for registration themselves in accordance with GACC requirements.

Traders should note that as required by the GACC, original equipment manufacturers (OEMs) or brand name owners should determine the place of origin of a product in accordance with 《The Regulations of the People's Republic of China on the Place of Origin of Imported and Exported Goods》.  Entities of production, processing and storage with legal liabilities for their products directly exported to the Mainland should be registered in accordance with registration requirements. In declaring food imports, they should fill in the China registration number of the manufacturer registered in the place of origin.

GACC Official Website Information on "Registration Regulations" and "Administrative Measures"

Frequently Asked Questions

Q1:  What are the details of the "Registration Regulations" and "Administrative Measures"?
A1:  Please refer to the original texts of the Registration Regulations and Administrative Measures on the GACC website for details.

Q2:  Who are required to undergo registration?
A2:  Pursuant to Article 2 of the Registration Regulations, all overseas manufacturers of production, processing and storage (hereinafter referred to as "overseas manufacturers of imported foods") that export foods to Mainland China are required to register with the GACC.  Overseas manufacturers of imported foods do not include enterprises engaging in the production, processing and storage of food additives and food-related products.

Q3:  What categories of food need to be recommended by the competent authorities of their countries/regions for registration with the GACC?
A3:  According to Article 7 of the Registration Regulations, for the following 18 categories of food, namely meat and meat products, sausage casings, aquatic products, dairy products, bird's nests and bird's nest products, bee products, eggs and egg products, edible oils and fats and oilseeds, stuffed pastry products, edible grains, milled grain industry products and malt, fresh and dehydrated vegetables and dried beans, condiments, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, food for special dietary purposes and health food products, the overseas manufacturers to be recommended for registration shall be examined and inspected by the competent authorities of their countries/regions.  After confirming that the overseas manufacturers conform with the registration requirements, the authorities can make the recommendation by providing the necessary application materials and reports to the GACC.  The GACC has different registration requirements for manufacturers of different foods.  The factors of consideration include sources of food ingredients, food production and processing technologies, previous food safety records, consumer groups, modes of consumption, etc.  As for overseas manufacturers of foods other than the 18 categories, they can visit the China International Trade Single Window and use the simplified "self-application by enterprise" mode to apply for registration with the GACC.  The GACC has published on its official website a guide to handling government affairs service matters related to Registration of Overseas Manufacturers of Imported Foods to explain the registration process for the related enterprises.

Q4:  How can I tell if my food products fall into the 18 food categories?
A4:  You can visit the China International Trade Single Window for information about the food categories concerned.  After creating an account, you can see the food classifications and HS codes for registration.

Q5:  How can overseas manufacturers of foods other than the 18 food categories undergo registration?
A5:  Overseas manufacturers of foods other than the 18 food categories can visit the China International Trade Single Window and use the simplified "self-application by enterprise" mode to apply for registration with the GACC.  For details, please refer to the guide to handling government affairs service matters related to Registration of Overseas Manufacturers of Imported Foods on the GACC website.

Q6:  How should I fill in the column "registration number approved by the competent authorities of the country (region)" in the China Import Food Enterprise Registration System of the GACC?
A6:  Food manufacturing/processing enterprises are suggested to use their Food Factory Licence Numbers issued by the Food and Environmental Hygiene Department as the registration numbers.  For enterprises not requiring a Food Factory Licence for food processing, their Factory Registration Numbers issued by the Trade and Industry Department or Hong Kong Business Registration Numbers can be used as the registration numbers for identification purpose.

Q7:  Should food manufacturing/processing enterprises engaging in the production of a variety of foods apply for a registration number in respect of each category of food?
A7:  Food manufacturing/processing enterprises engaging in the production of a variety of foods are required to apply for a registration number for each category of food.  If a number of food manufacturing/processing enterprises are producing the same category of food at the same time, the same registration number cannot be shared.  If a certain category of food is jointly produced by a number of food manufacturing/processing enterprises, the enterprise that completes the food manufacturing/processing operation should apply for a registration number for the food.  The OEM or the brand name owner should determine the place of origin of a product in accordance with the Regulations of the People's Republic of China on Origin of Imported and Exported Products.  Entities of production, processing and storage with legal liabilities for their products directly exported to the Mainland should be registered under the registration requirements.  In declaring food imports, they should fill in the Chinese registration number of the manufacturer registered in the place of origin.