China GACC Clarifies Decree No. 280: Three Registration Changes for Overseas Food Manufacturers

What Changed at a Glance

How Announcement No. 27 Fits with Decree No. 280

Decree No. 280 establishes the governing registration framework, including registration pathways, application requirements, supervision, amendment, renewal, suspension, cancellation, and revocation. Announcement No. 27 provides the supporting catalogue and lists, defines the relevant overseas storage-enterprise scope, and sets detailed import declaration and information-query rules.

The catalogue, the non-automatic-renewal list, and the storage-enterprise scope are subject to dynamic management. Companies should therefore treat the March 2026 announcement as the current operating basis, while continuing to monitor CIFER and GACC updates rather than relying on a permanently fixed product list.

Change 1: Official-Recommendation Registration Moves from 18 to 17 Categories

Announcement No. 27 identifies 17 food categories or category ranges for which the overseas manufacturer must obtain supporting documents from the competent authority of the exporting country or region. Under Decree No. 280, the manufacturer may submit the application itself or appoint an agent, but catalogue-listed foods additionally require an official inspection report and recommendation letter. This is different from saying that the competent authority must always submit the enterprise's application on its behalf.

The current catalogue covers: meat and meat products; casings; bird's nest and bird's nest products; bee products; eggs and egg products; edible oils and fats; stuffed flour-based foods; edible grains; grain-milling products and malt; dehydrated vegetables; seasoning powders; nuts and seeds; dried fruits; foods for special dietary uses; health foods; dairy products; and aquatic products.

GACC's official interpretation describes the change as an adjustment from 18 to 17 categories. Unroasted coffee beans and cocoa beans were removed as a standalone category, while the scope of oilseeds, coarse grains, fresh vegetables, dried beans, and seasonings was narrowed. Products removed from the catalogue should not automatically be treated as deregulated: relevant primary edible agricultural products remain subject to the separate overseas-enterprise registration and declaration arrangements under GACC Announcement No. 219 of 2025.

Change 2: Automatic Renewal Becomes the General Rule, but Not an Unconditional One

Under Article 21 of Decree No. 280, a registration generally renews automatically for another five years when it expires. Automatic renewal does not apply in any of the following circumstances:

the food is included in GACC's non-automatic-renewal list;

the enterprise is undergoing rectification because it does not meet registration requirements; or

GACC has lawfully suspended imports of the relevant food from the enterprise's country or region.

Announcement No. 27 currently places two product groups on the non-automatic-renewal list: meat and meat products, and bird's nest and bird's nest products. Manufacturers in these groups that intend to continue exporting to China must apply for renewal through the applicable registration channel between 3 and 12 months before the registration expires. For catalogue-listed foods, the renewal materials also include a statement from the competent authority confirming continued compliance with the registration requirements.

The practical takeaway is that “automatic renewal” should not be interpreted as “no maintenance required.” Every registered enterprise should still monitor its expiry date, rectification status, country-level import measures, and material changes to its registered information.

Change 3: GACC Clarifies Cold-Store Scope and Customs Declaration Rules

Decree No. 280 applies to overseas enterprises engaged in the production, processing, or storage of food exported to China. Announcement No. 27 now specifies which overseas storage enterprises fall within the registration regime: cold stores used for terrestrial animal-origin foods and aquatic products. Operators should assess the actual storage function and product scope rather than assuming that every overseas warehouse is covered.

For food imported as cargo for human consumption in China or for use as a food-processing ingredient, the customs declaration must:

enter the China registration number of the overseas manufacturer corresponding to the declared country or region of origin in the “Registration of Overseas Manufacturers of Imported Food” certificate field under “Product Qualification” (licence category code 519); and

enter “Edible” in the “Use” field under the commodity declaration section.

GACC states that customs will not accept a declaration that is not completed as required. False information used to obtain customs documents may be investigated and handled in accordance with law.

The announcement also distinguishes when goods may still be declared based on the enterprise's registration status:

Official-recommendation route: products manufactured during the registration's validity period may be declared, including products still within shelf life that were manufactured before a registration expired without renewal.

Enterprise-application route: the enterprise's registration must be valid when the import declaration is made.

Suspended, cancelled, or revoked registrations: food dispatched before the effective date of the suspension, cancellation, or revocation is not affected by that status change, unless GACC imposes a special requirement.

Priority Actions for Overseas Manufacturers and Importers

Reconfirm product classification.

Use the CIFER product-category query together with the product description, processing method, HS code, and CIQ code. Do not rely only on the product's commercial name.

Map the correct application route.

Determine whether the product requires enterprise application, official supporting documents, or may qualify for list-based registration under an applicable bilateral arrangement.

Audit renewal eligibility.

Check the food category, expiry date, rectification status, and any country-level import suspension. Build a proactive renewal plan where automatic renewal is unavailable.

Check cold-chain entities.

Identify cold stores handling terrestrial animal-origin foods or aquatic products and confirm whether their facility information and registration status align with the shipment plan.

Align declaration data across the supply chain.

Manufacturers, exporters, importers, and customs brokers should verify the country or region of origin, facility registration number, product category, shipment timing, and declaration fields before filing.

How REACH24H Can Help

REACH24H supports overseas food manufacturers, processors, storage facilities, and food brands with GACC/CIFER pathway assessment, product-category and HS/CIQ code review, application-document preparation, system submission support, coordination with competent authorities where required, and post-registration maintenance such as amendment and renewal planning.

If you need to verify whether a facility or product falls within the 17-category catalogue, assess renewal eligibility, or check declaration readiness, explore our GACC Registration for Food Export to China service.