14 April 2021 - On 12th of April 2021, the General Administration of Customs P.R. China (GACC), has announced two major updates of regulations, both of which concern food products imported into China:
· Announcement 248: New version of Registration and Management Rules of Overseas Manufacturers of Imported Food
· Announcement 249: New version of Administrative Rules of Imported Food Safety
Both Rules will officially be enforced starting from 1st of January 2022.
These new rules have many changes compared to their preceding versions. Announcement 249 has abolished 6 rules related to import/export of food, including the separate rules for aquatic products, meat, and dairy products. The new Administrative Rules of Imported Food Safety has effectively combined all these different old rules together so both the authorities and food product related operators can refer to one rule.
The new rules have many new specific details implemented. For example, video inspections are now officially stated as one of the methods that the GACC may use to carry out audits on a country, area, or manufacturer’s food safety management system. This may greatly increase the efficiency as audits are not limited to on-site inspections only.
Announcement 249 has significant changes on the registration requirement for food manufacturers which wish to export to China. Previously only several high-risk food categories, including aquatic products, meat, and dairy products, are required to be registered at the GACC, and only via recommendation by the competent authority of the manufacturer. The new rule has effectively expanded the food categories to all:
Food Manufacturers of Imported Food, should be registered at the GACC.
The rule has further separated this into two different types of registration procedure:
Via the overseas competent authority only: aside from the previously mentioned aquatic products, meat, and dairy products (including formula food), this has been expanded to in total 18 food categories, including: meat and meat products, casings, aquatic products, dairy products, bird's nest and bird's nest products, bee products, eggs and egg products, edible fats and oils, stuffed pasta, edible grains, grain milling industrial products and malt, fresh and dehydrated vegetables and dried beans, seasonings, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, special dietary foods, and health foods.
Via the manufacturer or agency: for other food categories, manufacturers should apply for registration at the GACC themselves or via their agent.
For both types of procedure, manufacturers are expected to receive inspection by the GACC. The inspection method could be via written information, video, onsite, or a combination of them. It is expected that the GACC will publish further details of the application procedure and inspection requirement in the short future.
Both rules will have great impact on European food manufacturers who are already exporting to China or planning to do so. Manufacturers will have greater responsibility on obtaining their permission to export to China, including to provide a guarantee of their products to comply with the Chinese relevant laws, regulations, and food safety standards. In addition, the expanded scope of registration implies that every food manufacturer should be prepared to receive inspection by the GACC.
What can CCIC do for you?
CCIC is the strongest expert in regulatory affairs concerning food exporting to China. We possess a great wealth of information in Chinese food safety regulations and standards, and our consultants have excellent experience handling Chinese official affairs from interpretation during official meetings to participating in audits. Our service has helped European food manufacturers to be better trained and prepared for official inspections, discover gaps, and prevent misunderstandings due to cultural differences.
CCIC consulting services related to registration at the GACC include but are not limited to:
· Training of the latest Chinese National Standards and its implementation into your food safety management system and your products.
· Food product analytic service to check against compliance requirement.
· Factory pre-audit to discover or prevent potential gaps.
· Support in the official application of registration.
· Support during video and/or onsite official inspections.
· Strategic consulting for market access of China.
Should you have interest in understanding the new rules and see how we can help you prepare for it, please contact us: firstname.lastname@example.org; email@example.com or give us a call at +44 (0)20 8445 3209.