Introduction

For overseas food enterprises looking to enter the Chinese market, ensuring the safety of imported food is their primary responsibility.

Reach24H focuses on practical operations for enterprises and deeply breaks down the three-stage governance system constructed by China Customs: "strict access before import, strict inspection and quarantine during import, and strict follow-up supervision after import", helping food products and raw materials enter the Chinese market smoothly.

When importing food, it will go through five core checkpoints:

• Conformity assessment: Conformity assessment from national systems to enterprise qualifications

• Designated ports and supervision sites: High-risk foods such as meat/aquatic products must go through "exclusive channels"

• On-site inspection at ports: 7 key inspection points need attention

• Chinese label management: Pre-packaged foods must meet label requirements

• Disposal of unqualified products: Safety-related issues result in direct return

How Is Conformity Assessment Conducted for Imported Food?

System Overview

The customs implements conformity assessment on imported food in accordance with the provisions of laws and administrative regulations related to import and export commodity inspection.

Regulatory Content

The conformity assessment of imported food covers the entire process, specifically including:

Pre-import control

◦     Assessment and review of the food safety management system of overseas countries/regions

◦     Registration of overseas production enterprises

◦     Filing of importers and exporters and qualification guarantee

◦     Quarantine approval for entry of animal and plant-derived food

Verification during import

◦     Inspection of accompanying qualification certificates

◦     Document review

◦     On-site inspection at ports

◦     Supervision and sampling inspection

Tracking after import

◦     Inspection of import and sales records

◦     Assessment conclusion: Foods that pass the comprehensive assessment by the customs can be allowed to be imported.

Designated Ports and Supervision Sites for High-Risk Imported Foods

System Overview

Based on risk management, high-risk foods are subject to entry through designated ports and inspection at designated sites (the list is dynamically announced by the General Administration of Customs).

Regulatory Content

• Applicable products: Imported meat, chilled aquatic products, grains (excluding rice), etc.

• Supervision of designated regulatory operation sites: On the basis of risk assessment, the customs may designate regulatory operation sites for inspection, examination and quarantine of some foods.

• Supervision of designated or recognized places for imported food: After arriving at the port, imported food shall be stored in places designated or recognized by the customs; if it needs to be moved, it must be permitted by the customs and necessary safety protection measures shall be taken in accordance with the requirements of the customs.

• Supervision of bulk imported food: Bulk imported food shall be inspected at the unloading port in accordance with the requirements of the customs.

On-Site Inspection at Ports

System Overview

The customs conducts on-site inspection based on risk management needs, in accordance with Chinese laws and national food safety standards.

Regulatory Content

The customs carries out on-site inspection on imported food according to the needs of supervision and management. The on-site inspection includes but is not limited to the following contents:

• Whether the means of transport and storage places meet safety and health requirements;

• Whether the container number, seal number, marking content on internal and external packaging, and the actual condition of the goods are consistent with the declared information and accompanying documents;

• Whether animal and plant-derived foods, packaging materials and cushioning materials are in the situations specified in Article 22 of the "Regulations for the Implementation of the Law on the Entry-Exit Animal and Plant Quarantine";

• Whether the internal and external packaging meets national food safety standards, and whether there is pollution, damage, wetting or penetration;

• Whether the labels, marks and instructions on internal and external packaging meet the requirements of laws, administrative regulations, national food safety standards and the provisions of the General Administration of Customs;

• Whether the sensory properties of the food are in line with the due properties of the food;

• Whether the freshness, central temperature of frozen and refrigerated food meet the requirements, whether there is pathological changes, whether the temperature of the frozen and refrigerated environment meets the requirements of relevant standards, whether the cold chain temperature control equipment and facilities operate normally, and whether the temperature records meet the requirements. If necessary, cooking tests can be carried out.

Chinese Label Management

System Overview

The packaging, labels and marks of imported food must comply with Chinese laws, regulations and national food safety standards; foods that are legally required to have instructions must be equipped with Chinese instructions.

Labels and instructions must simultaneously meet the following requirements:

• Comply with the requirements of Chinese laws, administrative regulations and national food safety standards;

• Clearly mark the origin of the food;

• Indicate the name, address and contact information of the domestic agent.

Pre-packaged food shall not be imported in any of the following circumstances:

• Without Chinese labels or Chinese instructions;

• Labels/instructions do not meet the above regulations.

Regulatory Content

Label requirements by category (must-see for overseas production enterprises):

• Fresh and frozen meat

For imported fresh and frozen meat products, the internal and external packaging shall have firm, clear and legible labels in Chinese and English or in Chinese and the language of the exporting country (region).

The following contents shall be indicated:

Country (region) of origin, product name, registration number of the production enterprise, production batch number; the outer packaging shall be marked in Chinese with specifications, origin (specific to state/province/city), destination, production date, shelf life, storage temperature, etc. It must be marked that the destination is the People's Republic of China, and the official inspection and quarantine mark of the exporting country (region) shall be affixed.

• Aquatic products

For imported aquatic products, the internal and external packaging shall have firm, clear and legible labels in Chinese and English or in Chinese and the language of the exporting country (region).

The following contents shall be indicated:

Commercial name and scientific name, specifications, production date, batch number, shelf life and storage conditions, production method (marine fishing, freshwater fishing, aquaculture), production area (marine fishing waters, freshwater fishing country or region, country or region where aquaculture products are located), names, registration numbers and addresses (specific to state/province/city) of all involved production and processing enterprises (including fishing vessels, processing vessels, transport vessels and independent cold storage), and it must be marked that the destination is the People's Republic of China.

• Health food and special dietary food

Chinese labels must be directly printed on the smallest sales package (not allowed to be affixed).

• Special marking regulations

Implemented in accordance with the special management regulations for relevant products.

• Ordinary pre-packaged food

Implemented in accordance with national standards such as GB 7718 (General Rules for Labels of Pre-packaged Foods) and GB 28050 (General Rules for Nutrition Labels).

How to Dispose of Unqualified Imported Food?

System Overview

The customs conducts conformity assessment on imported food in accordance with international rules and Chinese laws.

Regulatory Requirements

1.   If imported food fails to pass the customs conformity assessment, the customs shall issue a certificate of unqualified products;

2.   If the unqualified items involve safety, health and environmental protection, the customs shall notify the food importer in writing and order it to destroy or return the food;

3.   If other items are unqualified, the food can be imported only after technical treatment to meet the requirements of conformity assessment.

If the relevant imported food cannot complete the technical treatment within the specified time or still fails to pass after technical treatment, the customs shall order the food importer to destroy or return it.

Recommendations from Reach24H for Enterprises

Advance verification:

• Confirm the qualification of designated ports for high-risk products

• Pre-check Chinese labels in accordance with GB 7718

On-site preparation:

• Prepare real-time temperature records for cold chain food

• Ensure that the physical goods are consistent with the declared information and accompanying documents

Risk prevention and control:

• Regularly check the customs' early warning notices on unqualified food