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New Regulations for Overseas Food Exporters to China
1.1.2022

Starting from 1 January 2022 new regulations have come into effect for overseas food exporters to China. Food companies and brands have to register their company at the General Administration of China Customs (GACC) and may also have to adjust their packaging.  

The new regulation was issued to implement provisions of the Food Safety Law on the registration of overseas food production enterprises importing food into China. It extends the registration scope of food production enterprises to all food manufacturers, processors and storage facilities. The product scope includes all food products, except food additives and food-related products, which are defined by the Food Safety Law of China as food packaging materials, detergents, disinfectants, and tools and equipment used in food production.  

The registration procedure depends on the product category:

  • Group No.1: 18 categories of food for which registration is recommended by the competent authority of the country of origin, 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 fat and oil; stuffed pasta; edible cereals; industrial grain milling products and malt; fresh and dehydrated vegetables and dried beans; seasonings; nuts and seeds; dried fruits; unroasted coffee beans and cocoa beans; special diet foods; and health foods.
  • Group No.2: Other foods not covered by the above 18 categories.

Factories manufacturing products covered by Group No.1 must first obtain recommendation from the competent authority (defined as the government agency responsible for food safety) of the local jurisdiction to register the factory. There are also detailed requirements for the registration dossier including, if required, food safety documents, facility design, and manufacturing process flow chart. Facilities manufacturing products covered by Group No.2 may apply directly for facility registration with less stringent document requirements.

Once the new regulation is implemented, the GACC has more administrative enforcement tools regarding food import, for example when there is a major animal or plant disease outbreak or a significant change in the food safety situation in the exporting country. Or when the overseas production facility violates relevant Chinese laws and regulations. 

Foreign brands exporting to China should pay particular attention to the section in the new policy regarding packaging regulations for certain types of products. Compared to the previous regulations on imported food introduced in 2013, the range of products requiring printed Chinese labels on their sales packages has been extended to include sports nutrition, supplementary food for infants, supplementary food for pregnant women and nursing mothers, formula products for medical use, and imported health foods. 

Selling through cross-border e-commerce (CBEC) channels could be a worthwhile alternative, as the new regulation on imported food product packaging does not apply to CBEC. Brands which cannot take timely action to comply to the new regulation, may still sell the stock originally scheduled for general import through CBEC channels. In the meantime, overseas food exporters can prepare for future export under the general trade model. 

Furthermore, selling products through CBEC channels such as Tmall Global offers overseas food brands additional benefits. The CBEC platforms where brands offer their products can give Chinese consumers additional confidence because they trust the platforms. This is especially true for food products with limited brand recognition and presence in the market. Stores on the CBEC platforms will be owned by the brand rather than local distributors, giving brands more control over in-market branding and ROI. More details about CBEC can be found at https://www.horsten.be/tmall-flagships-store/.

Please contact us if you would like more information about this new regulation or if you need assistance.

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