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Interpretation | Regulations on the Administration of Registration of Overseas Manufacturers of Imported Foods (Draft)


Jan 01, 2020

On November 26, 2019, the General Administration of Customs (GACC) solicited public opinions on the Regulations on the Administrationof Registration of Overseas Manufacturers of imported Foods (Draft). The deadline for opinions is December 25,2019.

After thorough study and comparison with the current version of the regulation, Global FOODMATE highlighted few key points appeared in the draft version of the regulation, for your reference.

1. Registration scope planned to be expanded to all imported foods

Provisions relating to the Directory of the Implementation of the Registration of Overseas Manufacturers of imported Food (hereinafter referred to as “Directory”) were not shown in the draft version, related content was replaced by “Overseas Manufacturers of imported Food that export food to china shall obtain the registration approval from GACC”.

 Currently, overseas manufacturers of dairy products (excluding infant formula), infant formula, meat products, aquatic products and edible bird’s nest need to apply for registration before they export food to China. In the future, overseas manufacturers of all imported food might be required to obtain the registration approval. Meanwhile, a registration management based by category might be implemented by GACC. 

2. Highlighted the supervision and management responsibilities of the competent authority of the exporting country in the entire registration process

The draft version stipulated in details, regarding the supervision and management responsibilities of the exporting country's competent authority before, during and after the registration of overseas manufacturers of imported food. Also, Article 21 stipulated the measures need to be taken when inadequate supervision of the competent authority of the country occurs.

3. Planned to determine emphasis, method and frequency of supervision and inspection for registered manufacturers based on different risk levels

For the first time, the draft version proposed the annual verification and reporting system, replacing the regular review system, as a supervision and management means. That is, for imported food with higher levels in food safety risks and in consumer sensitivity, GACC will implement annual verification and reporting systems to corresponding registered overseas manufacturers.

4. Possible changes of registration dossiers

Planned to request: The inspection report of the company issued by the competent authority of the country, a statement that the company promises that its sanitary conditions and production process can continue to meet Chinese requirements.

Planned to neglect: No more requirements for business registration applications and the relevant floor plans and production processes.

5. Validation of Registration certification planned to be extended to 5 years

Validation was replaced by 5 years in the draftversion, instead of 4 years in the current version.

6. Planned to display the information of manufacturer on the label of imported food

The draft version stipulated that registered manufacturers of imported food shall truthfully mark the registration number, name and address of the manufacturer on the minimum sales package of food exported to China. Currently, only registration number of the manufacturer is required to be labelled on the outer package of the food.

7. Highlighted the responsibilities of the importers

The draft version stated that importers shall establish an audit system for imported food manufacturers to ensure that imported food is produced by the registered manufacturer and the name, address and registration number of the manufacturer on the minimum sales package of food exported to China are true and accurate. In addition, the draft version also pointed out that the compliance situation of overseas manufacturers of imported food willbe recorded in the Customs credit management system.

It can be seen, to determine whether an imported food is legal and compliant is not only the responsibility of the Customs,also the primary responsibility of the importers. Overseas manufacturers need to strictly abide by relevant Chinese laws and regulations to ensure product compliance and safety, otherwise, the bad credit will affect the cost and efficiency of overseas manufacturers when exporting food to China.

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Please note: Original English article of Global Foodmate of Information Service and Business Department, please indicate the source from the Global Foodmate if reprint.

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