For the reason that spring of 2021, China has begun to reform its imported meals administration by issuing a number of packages of key govt orders, for instance, GAC Bylaw # 248, Laws for the Registration and Administration of Overseas Producers of Imported Meals.…1 In keeping with Decree No. 248, all abroad meals producers exporting meals to China after January 1, 2022 have to be registered prematurely with the GAC.2 On November 5, 2021, the Normal Administration of Customs of China (GAC) introduced additional clarifications in its Decoding the Laws for the Registration and Administration of Overseas Producers of Imported Meals (GAC Bylaw No. 248) (“Interpretation”)3…
The Interpretation clarifies the next key factors within the implementation of GAC Decree 248:
No transition interval
GAC Bylaw # 248 will enter into pressure on January 1, 2022, as introduced, and not using a transitional interval for the introduction of the abroad catering registration system.
Imported meals merchandise are labeled into two classes, ie “sure meals” and “different”, topic to completely different registration necessities. In keeping with the Interpretation, the corresponding Harmonized Desk (HS) codes for items falling into these two classes are introduced on the official GAC web site. As well as, the GAC will present software varieties and templates for registration functions from abroad companies to cowl the above meals classes.
The amount of the international meals fund
All international corporations taking part in manufacturing, processing and storage4 Meals exported to China is topic to GAC Bylaw # 248 and subsequently should fulfill its enterprise registration obligations. All companies, websites and fishing vessels concerned within the manufacturing and processing of meals are included.
Within the life cycle of imported meals, completely different objects overseas can be utilized for various functions, comparable to manufacturing, processing and storage. As mentioned in additional element under, GAC Bylaw # 248 requires all imported meals merchandise to have a enterprise registration quantity on their packaging. Due to this fact, it’s topic to additional clarification which or all of this stuff must be indicated on the label.
Registration quantity marking
Article 15 of Decision No. 248 prescribes to point the registration variety of the item on interior and outer packaging of merchandise exported to China. This quantity could also be issued by China or the competent authority of the exporting nation / area.
In keeping with the interpretation, “interior and outer packaging»Refers to transport packaging and impartial retailer packaging. If the unit offered consists of a number of models that may be offered independently and the registration quantity have to be on the Chinese language label, the China Nationwide Meals Security Customary is Normal Labeling Guidelines for Prepackaged Meals (GB 7718) applies. As a result of this, the present GB 77185 requires every impartial resale unit to be individually marked.6 It’s noteworthy that GB 7718 is at present below revision, so it’s doubtless that the revised GB 7718 can have further particulars about this requirement.
Whereas the Interpretation confirms that the bell will ring on January 1 subsequent 12 months to implement the abroad enterprise registration system, alongside the way in which, the GAC must shed extra mild on some unresolved sensible points comparable to competent brokers for “different meals”. ”Registrants, registration quantity to be declared for meals processed at a number of websites, and many others. These points are prone to change into related when the trade begins to adjust to registration necessities with the assist of native authorities. For instance, the US Meals and Drug Administration (FDA) has raised sure questions with the Chinese language authorities relating to the registration necessities for brand spanking new websites below GAC Ordinance No. beneficial by the competent authority. Accordingly, the GAC plans to publish steering on which registration procedures apply to particular HS codes.
 GAC Bylaw No. 248; Official English model
 See our Regulatory Information Alerts – China Regulatory Points for extra data. Breaking Information: China Introduces New Registration Necessities For All Overseas Meals Corporations And China Abroad Meals Enterprise Registration: Some Deadlines You Want To Know About.
 Companies that personal premises and containers appropriate for storing meals and retailer meals in accordance with security and sanitation necessities.
 GB 7718-2011 Normal Guidelines for Labeling of Prepackaged Meals – Questions and Solutions (Revised)