China has stringent protocols in place for manufacturers wanting to export their food products into their country.
China’s General Administration of Customs (GACC) is responsible for managing the registration of overseas manufacturers of imported foods and the interpretation of Decree 248; the legislation that sets out the registration requirements.
Decree 248 was released by GACC, in Quarter 2 of 2021 and came into effect on 1st January 2022.
What Is Decree 248?
Decree 248 requires that all overseas manufacturers of foods that are imported into China, need to obtain GACC registration. That is, all food products must be approved via the GACC registration process. Decree 248 also requires that registration labelling requirements are met.
Which Food Products Require GACC Registration?
If you manufacture the following food products, you will need to complete your GACC registration via the Ministry for Primary Industries (MPI) Recommended Registration process:
1. Meat and meat products
3. Aquatic products
4. Dairy products (including dairy-based infant formula products)
5. Edible fats and oils
6. Bee products
7. Milled Grain industry products and Malt
8. Fresh and dehydrated Vegetables and Dried Beans
9. Foods for special dietary purpose
10. Health foods (Functional foods)
11. Birds nest and products
12. Eggs and egg products
13. Stuffed pasta
14. Edible grains
16. Nuts and seeds
17. Dried fruits
18. Unroasted coffee beans and cocoa beans
If you manufacture other food products not listed in the above categories, such as fruit juice, confectionary, wine, and most processed foods, you are able to use the self-registration process.
Also of importance is that there are labelling requirements for all these products that must be met and approved.
Which Foods are Exempt?
- Food additives and food-related products (e.g. food packaging)
- Exporters not involved in manufacturing/storing
- Ambient stores that do not process/pack/re-pack are exempt from this requirement.
The Registration Process
For food manufacturers based in New Zealand, there are two methods of registration – depending on the product category that you manufacture.
Refer F14/22 China Registration of Food Manufacturing Premises
- Manufacturer A – Ministry for Primary Industries (MPI) recommended registration
- 18 designated product categories
- Manufacturer B – Self-registration
- If the product is not one of the 18 product categories and is listed for self-registration
The above linked MPI document will also provide you with background information on the criteria for your product type and the registration process.
Registration for both of the above methods is undertaken on the CIFER on-line platform. (China Imported Food Enterprises Registration) https://cifer.singlewindow.cn
China Registration Number
It is critical that you use the new China Registration number for import declarations. There is one user account (login) per premises / MPI registration and one China registration per product category.
The new China Registration Number has the following format: CNZLxxxxyymmddzzzz
- CNZL – is unique to New Zealand
- xxxx – indicates the product category
- yymmdd – indicates the date of registration
- zzzz – the serial number
Both registration options require a number of activities to be undertaken to initiate and implement your registration.
However, the MPI recommended registrations have specific (and in some cases new) registration conditions per product category that must be worked through by the food producer.
What Assistance Does Produco Provide?
Our team has been working with our clients in the dairy and food industries providing guidance and technical assistance to navigate them through the GACC registration processes. This includes the new registration conditions and submissions to the Regulators and providing a GAP assessment of your registration process to verifiers.
We have the knowledge and technical expertise in these areas and can help take the complexity out of the process for you!
The Ministry for Primary Industries (MPI) has set up dedicated email addresses to support your registration process.
– If you require an MPI Recommended Registration for the China Country Listings email: [email protected]
– For Food Producers who will use Self-Registration as an option, the Exporter Advisory Services team can assist: [email protected]
GACC Registrations Do Expire
GACC registrations are valid for 5 years.
• The expiry date can be found in your current GACC registration
• You can apply to renew the GACC registration from 3-6 months before the expiry date (directly or via MPI).