Imported Food Customs Clearance in China: Market Access, Registration & Quarantine

Assessment and Review of Food Safety Management Systems of Exporting Countries (Regions)

System Overview

The General Administration of Customs of China (GACC), in accordance with the principles of risk management, conducts an assessment of the completeness and effectiveness of the food safety management system of the exporting country (region) that intends to export food to China. The assessment serves to determine:

• Whether the food safety management system and the overall food safety status of the exporting country (region) meet the level required by China;

• Whether the food produced under that system for export to China is in compliance with the statutory requirements of Chinese laws and regulations and the National Food Safety Standards of China.

Process Overview

Initiation of Assessment and Review

GACC will initiate an assessment and review of an exporting country (region) under any of the following circumstances:

• The exporting country (region) applies to export a category (or type) of food to China for the first time;

• There are significant changes to the food safety, animal and plant quarantine laws, regulations, or organizational structures of the exporting country (region);

• The competent authority of the exporting country (region) applies for major adjustments to the inspection and quarantine requirements for a category (or type) of food exported to China;

• A major animal or plant epidemic or a food safety incident occurs in the exporting country (region);

• GACC identifies serious issues in food products exported to China, giving rise to concerns over animal or plant epidemic risks or food safety hazards.

Assessment Content

The assessment and review of the food safety management system of the exporting country (region) primarily includes the evaluation and confirmation of the following elements:

• Laws and regulations pertaining to food safety and animal and plant quarantine;

• Organizational structure for food safety supervision and administration;

• Prevalence of animal and plant diseases and the corresponding prevention and control measures;

• Management and control of pathogenic microorganisms, agricultural and veterinary drugs, and contaminants;

• Hygiene and safety controls throughout food production, processing, transportation, and storage;

• Safety supervision and administration of exported foods;

• Food safety protection, traceability, and recall systems;

• Early warning and emergency response mechanisms;

• Technical support capabilities;

• Other matters involving animal and plant epidemics or food safety concerns.

Assessment and Review Process

GACC organizes experts to review the application documents and completed written assessment questionnaires submitted by the country (region) under assessment, with a primary focus on examining their authenticity, completeness, and validity.

Based on the review results, GACC may require the competent authority of the country (region) concerned to:

• Supplement any missing information; or

• (For those that have passed the documentary review) undergo a video inspection or on-site inspection of its food safety management system.

Any non-compliances identified during the inspection shall be subject to corrective actions by the competent authority and the enterprises of the country (region) concerned.

Notification and Publication of Results

Upon completion of the assessment and review, GACC will notify the competent authority of the country (region) concerned of the results.

Products that meet the established requirements will be approved for inclusion in the Catalogue of Food Exported to China from Countries or Regions that Meet the Assessment and Review Requirements or Have Traditional Trading Relationships, and will be permitted for export to China.

Registration Management System for Overseas Food Production Enterprises

System Overview

Pursuant to GACC Decree No. 280 (the Regulations of the People's Republic of China on Registration Administration of Overseas Production Enterprises of Imported Foods), which took effect on June 1, 2026, and replaced the former Decree No. 248, GACC conducts reviews of overseas food production enterprises recommended by the competent authorities of their exporting countries (regions) for export to China.

Enterprises that satisfy the prescribed requirements will be granted registration and publicly announced on the GACC official website.

Process Overview

The following 17 categories of imported food require official recommendation for registration: meat and meat products, casings, edible bird's nest and bird's nest products, bee products, eggs and egg products, edible fats and oils, stuffed pasta and pastry products, edible cereals, cereal 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.

Imported food categories other than the above 17 do not require official recommendation; enterprises may apply for registration directly on their own behalf or through an authorized representative.

Process Description

1) Enterprise Application Registration

Under this general pathway, the documentation requirements differ depending on whether the product falls within the 17 categories subject to official recommendation:

For products in the 17 categories requiring official recommendation, the competent authority of the exporting country (region) shall conduct an audit and inspection of the enterprises it intends to recommend for registration. Upon confirming that the enterprises meet the registration requirements, the competent authority shall submit a recommendation to GACC together with the following application documents:

• A letter of recommendation from the competent authority of the exporting country (region);

• A list of the enterprises and their registration application forms;

• Corporate identification documents, such as business licenses or equivalent certificates issued by the competent authority of the exporting country (region);

• A declaration by the competent authority of the exporting country (region) confirming that the recommended enterprises comply with the requirements set forth in these Provisions;

• An audit and inspection report prepared by the competent authority of the exporting country (region) on the enterprises under review;

• Where necessary, GACC may require the submission of the enterprises' food safety, hygiene, and food defense system documentation, including but not limited to floor plans of the manufacturing premises, workshops, and cold storage facilities, as well as process flow diagrams.

For products not listed in the 17 categories, enterprises may apply for registration directly with GACC either on their own behalf or through an authorized representative, without the need for a recommendation from the competent authority of the exporting country (region). This streamlined procedure significantly reduces the administrative burden of the application process.

Application Documents:

• Enterprise registration application form;

• Corporate identification documents, such as business licenses or equivalent certificates issued by the competent authority of the exporting country (region);

• A declaration by the enterprise committing to compliance with the requirements set forth in these Provisions.

• Where representation is authorized, the following additional document shall be submitted: A power of attorney, including information of both parties, scope of authorization, and period of validity.

Notes:

• The representative may be a legally established entity or individual, whether domestic or foreign;

• Any change to the principal-agent relationship shall be communicated to GACC in writing.

2) List Registration: For Countries (Regions) Covered by Specific Bilateral Regulatory Cooperation Arrangements

Decree No. 280 introduces and clarifies a new "list registration" mechanism. Where the food safety management system of the exporting country (region) has been recognized by GACC and meets the requirements under relevant bilateral cooperation instruments, agreements, memoranda, joint statements, or GACC risk assessment criteria, GACC may, through written agreement with the competent authority of that country (region), apply the list registration method to the relevant enterprises.

Under this pathway, the competent authority of the exporting country (region) submits to GACC a list of recommended enterprises, the enterprises' application information, a declaration confirming that the recommended enterprises meet the registration requirements, and a declaration of continued compliance with obligations under the bilateral cooperation instruments. GACC then reviews the list and grants registration and official GACC registration numbers to eligible enterprises on the list.

It should be noted that list registration is not a "fast track" that enterprises can opt into at their own discretion. Its applicability depends on the recognition of the exporting country (region)'s food safety regulatory system, the existence of bilateral regulatory cooperation arrangements, the recommendation mechanism of the competent authority, and whether the enterprises themselves meet the registration requirements under Decree No. 280.

Customs Examination Approaches

Document-Based Review: GACC examines the application documents and materials submitted by the enterprises or the competent authorities of the exporting countries (regions) to verify their authenticity and completeness.

Video Inspection: GACC conducts inspections of the enterprise's food safety and hygiene management system and its overall food safety and hygiene conditions through internet video conferencing.

On-Site Inspection: GACC deploys inspection teams to the overseas manufacturing facilities of the applicant enterprises to conduct on-the-ground verification of their food safety and hygiene management systems and related conditions.

Publication of Registration Results: Enterprises that meet the registration requirements shall be granted registration, and their registration status will be publicly announced on the official GACC website. Overseas food production enterprises that have obtained a GACC registration number are eligible to export food products to China.

Importer and Exporter Filing and Compliance Assurance

System Overview

Importer and Exporter Filing refers to the requirement that:

• Food importers domiciled in China, and

• Overseas exporters or agents exporting food to China,

shall file with GACC.

Compliance Assurance refers to the requirement that food importers or agents shall submit a written declaration or supporting documentation to GACC, confirming that the imported food:

• Complies with Chinese laws and regulations;

• Meets the National Food Safety Standards of China; and

• Fulfills the enterprise's primary responsibility for food safety.

Process Overview

Food importers shall file with the GACC office having jurisdiction over their place of domicile:

• Online Filing: Consignees of imported food and food importers may submit their filing applications to GACC through the International Trade "Single Window" or the "Internet + Customs" platform.

• Offline Filing: Food importers may also submit a paper-based Application Form for Consignee Filing together with the required supporting documents to the GACC office having jurisdiction over their place of domicile.

Administration of Official Certificates Accompanying Food Exported to China

The competent government authority of the exporting country (region) shall issue an official certificate for each consignment of food exported to China, in the format, content, and with the certification statements as determined through consultations with GACC.

Such certificate serves to attest that the exported food consignment has been effectively supervised under the official control system of the exporting country (region) and complies with the requirements of China. It includes, inter alia, animal health certificates, plant health certificates, and food hygiene certificates, as applicable.

Quarantine Approval System for Imported Food of Animal and Plant Origin

System Overview

To prevent the introduction of animal epidemics, parasitic diseases, and plant pests such as dangerous diseases, insects, and weeds, GACC implements quarantine approval management for imported food of animal and plant origin as explicitly stipulated in the Law of the People's Republic of China on the Entry and Exit Animals and Plants Quarantine and its supporting regulations.

Importers are required to apply to GACC in advance for the Entry Animal and Plant Quarantine Permit. During customs clearance, GACC will verify the permit and implement a utilization tracking (write-off) management system.

The specific product catalogue is subject to the provisions of the Administrative Measures for the Quarantine Approval of Imported Animals and Plants. In addition, importers should stay informed of the latest updates regarding the List of Direct Customs Offices Authorized to Conduct Quarantine Approval and Their Scope of Authority as issued by GACC.

Process Overview

For imported food subject to quarantine approval, the process is as follows:

• Timing and Applicant: The importer of the food to be exported to China, or its agent, shall submit an application for quarantine approval to the GACC office having jurisdiction over the port of entry prior to signing the trade contract for the consignment, and shall submit the required supporting documents in accordance with the applicable provisions.

• Approval Procedure: The quarantine approval process for entry food consists of three stages: acceptance of application, document review, and approval and issuance.

• Outcome: If the application meets the requirements, GACC or its directly affiliated customs office will issue the Entry Animal and Plant Quarantine Permit of the People's Republic of China, authorizing the importation of the consignment.

Policy Adjustment

In accordance with the Announcement on Adjusting the List of Imported Foods Subject to the Administration of Examination and Approval of Entry Plant and Animal Quarantine (GACC Announcement No. 158 of 2024):

Effective November 12, 2024, the following five categories of food for human consumption are no longer subject to quarantine approval procedures upon importation: cured meat products, casings, dairy products, aquatic products, and edible bird's nest (cubilose).

This adjustment has effectively streamlined the import process for these products and reduced associated time costs for enterprises.

REACH24H Action Guide for Enterprises

For food enterprises seeking to enter the Chinese market, thorough pre‑import preparation is the cornerstone of a successful market access strategy:

• Source Control: Strictly vet eligible countries (regions) of origin and registered suppliers—verify against the official directory and confirm registration numbers.

• Timely Filing: Complete the required filing procedures promptly and fulfill the compliance assurance obligations.

• Complete Documentation: Ensure that every shipment is accompanied by authentic and valid official certificates, and that the certificate information is fully consistent with the shipment details and declaration data.

• Stay Updated on Latest Policy Requirements: Pay special attention to changes in quarantine approval policies (such as the facilitative measures introduced by Announcement No. 158) and continuously monitor GACC regulatory updates.

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