Introduction

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

This article provides a comprehensive overview of the regulatory procedures that overseas food enterprises must understand and comply with before exporting to China.

From access assessment and manufacturer registration to importer filing, official certification, and quarantine approval, it explains each key system step by step—helping businesses ensure compliance, avoid customs delays, and achieve smooth market entry.

Before Food Import

The "before import" stage is the source of risk prevention and control, which is crucial. It is necessary to deeply understand and strictly abide by the following five core management systems:

• Access assessment: Assessment and review of the food safety management system of overseas countries (regions)

• Factory registration: Registration management of overseas manufacturers of imported food

• Filing and guarantee: Filing of importers and exporters and qualification guarantee

• Official certificates: Management of official certificates attached to food exported to China

• Quarantine approval: Quarantine approval system for imported animal and plant-derived food

Assessment and Review of Food Safety Management in Overseas Countries (Regions)

System Overview

The General Administration of Customs will, in accordance with the principle of risk management, assess the integrity and effectiveness of the food safety management system of overseas countries (regions) that intend to export food to China, so as to determine:

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

• Whether the food exported to China produced under this system can meet the requirements of Chinese laws and regulations and national food safety standards.

Process Introduction

1. Initiation of Assessment and Review

The General Administration of Customs will initiate assessment and review of an overseas country (region) under any of the following circumstances:

• An overseas country (region) applies to export a certain type (species) of food to China for the first time;

• Major adjustments have been made to the food safety, animal and plant quarantine laws and regulations, and organizational structure of an overseas country (region);

• The competent authority of an overseas country (region) applies for major adjustments to the inspection and quarantine requirements for a certain type (species) of food exported to China;

• A major animal or plant epidemic or food safety incident occurs in an overseas country (region);

• Customs finds serious problems in food imported into China and deems that there are animal or plant epidemic or food safety risks.

2. Assessment Content

The assessment and review of the food safety management system of an overseas country (region) mainly includes the assessment and confirmation of the following contents:

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

• Food safety supervision and management organizations;

• Prevalence of animal and plant epidemics and prevention and control measures;

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

• Safety and hygiene control in food production, processing, transportation, and storage links;

• Supervision and management of exported food safety;

• Food safety protection, traceability, and recall systems;

• Early warning and emergency mechanisms;

• Technical support capabilities;

• Other situations involving animal and plant epidemics and food safety.

3. Assessment and Review

The General Administration of Customs will organize experts to review the application materials and written assessment questionnaires submitted by the country (region) under assessment, focusing on their authenticity, completeness, and effectiveness.

Based on the review results, the General Administration of Customs may require the competent authority of the relevant country (region):

• To supplement missing information;

• Or (for those that pass the data review) to accept video inspections or on-site inspections of their food safety management systems.

For problems found during the inspection, the competent authorities and enterprises of the relevant countries (regions) will be required to rectify them.

4. Result Notification and Publication

After the completion of the assessment and review, the General Administration of Customs will notify the competent authority of the relevant country (region) of the results.

Products that meet the requirements will be allowed to be included in the "List of Countries or Regions Exporting Food to China That Meet the Assessment and Review Requirements and Have Traditional Trade", and will be permitted to export to China.

Registration Management System for Overseas Manufacturers of Imported Food

System Overview

In accordance with Order No. 248 of the General Administration of Customs (the "Regulations on the Registration Management of Overseas Manufacturers of Imported Food"), the General Administration of Customs reviews overseas food manufacturers recommended by overseas competent authorities for export to China.

Enterprises that meet the conditions will be approved for registration and publicized on the official website.

Scope of Application

Applicable Products: 18 categories of imported food

Meat and meat products, casings, aquatic products, dairy products, bird's nests and bird's nest products, bee products, eggs and egg products, edible oils and oilseeds, stuffed pasta, edible grains, grain milling industry products and malt, fresh and dehydrated vegetables and dried beans, condiments, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, special dietary foods, and health foods.

These require recommendation and registration by the official authorities of the country (region) where they are located.

For imported food categories other than the 18 categories, enterprises can apply for registration on their own.

Process Introduction

Registration Application for Overseas Manufacturers of 18 Categories of Imported Food

The competent authority of the country (region) where the enterprise is located shall conduct an audit and inspection of the enterprises it recommends for registration, confirm that they meet the registration requirements, then recommend them to the General Administration of Customs for registration and submit the following application materials:

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

• A list of enterprises and enterprise registration applications;

• Enterprise identity documents, such as business licenses issued by the competent authority of the country (region);

• A statement from the competent authority of the country (region) recommending that the enterprise meets the requirements of these regulations;

• Inspection reports on the audit and inspection of relevant enterprises by the competent authority of the country (region);

• If necessary, the General Administration of Customs may require the provision of documents on the enterprise's food safety and hygiene protection system, such as floor plans of the enterprise's factory area, workshops, cold storage, and process flow charts.

Registration for Overseas Manufacturers of Other Foods Beyond the 18 Categories

They can apply for registration to the General Administration of Customs on their own or through an agent, without the need for recommendation and registration by the competent authority of the country (region) where they are located, which further simplifies the application procedures.

Application Materials:

• Enterprise registration application;

• Enterprise identity documents, such as business licenses issued by the competent authority of the country (region);

• A statement of commitment by the enterprise to meet the requirements of these regulations.

• When entrusting an agent, the following shall be supplemented: a power of attorney (including information of both parties, matters and authorities, and validity period)

Note:

• The agent can be a legal domestic or foreign institution or individual;

• Any change in the agency relationship shall be notified to the customs in writing.

Customs Review Methods

• Documentary Inspection: The General Administration of Customs will inspect the application documents submitted by the enterprise or the competent authority of the country (region) to verify the authenticity and completeness of the application materials.

• Video Inspection: The General Administration of Customs will conduct inspections on the enterprise's food safety and hygiene management system and its food safety and hygiene status through internet video connection.

• On-site Inspection: The General Administration of Customs will go to the overseas production enterprises applying for registration to conduct on-site inspections and verifications of the enterprise's food safety and hygiene management system and its food safety and hygiene status.

• Publication of Registration Results: Those that meet the registration conditions will be approved for registration and publicly announced on the official website of the General Administration of Customs. Overseas manufacturers of imported food that have obtained registration numbers in China are allowed to export food to China.

Filing of Importers and Exporters of Food and Qualification Guarantee

System Overview

Filing of importers and exporters refers to domestic food importers in China and overseas exporters/agents exporting food to China shall file with the customs.

Qualification guarantee refers to food importers/agents submit written commitments or supporting materials to the customs to ensure that the imported food:

• Complies with Chinese laws and regulations

• Meets national food safety standards

• Fulfills the main responsibility for food safety of the enterprise

Process Introduction

Food importers shall file with the customs at their domicile:

• Online: Overseas exporters or agents of imported food and food importers can submit filing applications to the customs through the "Single Window" for international trade or the "Internet + Customs".

• Offline: Food importers can also submit the paper "Consignee Filing Application Form" and relevant materials to the customs at their domicile to apply for filing.

Management of Official Certificates Attached to Food Exported to China

Food exported to China's national or regional government competent authorities shall issue official certificates for each batch of food exported to China in accordance with the format, content, and certificate comments agreed with the General Administration of Customs.

These are used to prove that the batch of exported food has been effectively supervised under its official supervision system and meets China's requirements. They include: animal health, plant health, food hygiene certificates, etc.

Risk Warning: Missing certificates or inconsistent information will lead to customs clearance delays/return of goods.

Quarantine Approval System for Imported Animal and Plant-Derived Food

System Overview

To prevent the invasion of harmful organisms such as animal infectious diseases, parasitic diseases, and dangerous plant pests and weeds, the customs implement quarantine approval management for imported animal and plant-derived foods explicitly listed in the "Law on the Entry-Exit Animal and Plant Quarantine" and supporting regulations.

Importers must apply to the customs for an "Entry-Exit Animal and Plant Quarantine License" in advance, and the customs will verify the license and implement write-off management during customs clearance.

The specific product catalog shall be subject to the provisions of the "Measures for the Administration of Entry-Exit Animal and Plant Quarantine Approval", and attention shall also be paid to the latest "Notice on the List of Directly Affiliated Customs Authorized to Carry Out Quarantine Approval and Their Scope of Authority" issued by the General Administration of Customs.

Process Introduction

For imported food that requires quarantine approval, the process is as follows:

• Application Timing and Subject: Importers of food exported to China or their agents shall, before signing the trade contract for the batch of imported food, submit a quarantine approval application to the customs at the location of the import port and submit materials in accordance with regulations.

• Approval Links: The quarantine approval work for imported food is divided into three links: acceptance, review, and approval, and issuance.

• Result: Those that meet the requirements will be issued the "People's Republic of China Entry-Exit Animal and Plant Quarantine License" by the General Administration of Customs or directly affiliated customs, allowing import.

Latest Policy Adjustments

According to the provisions of the "Announcement on Adjusting the List of Imported Foods Subject to Entry-Exit Animal and Plant Quarantine Approval Management" (Announcement No. 158 [2024] of the General Administration of Customs):

Starting from November 12, 2024, imported pickled meat products for human consumption, casings, dairy products, aquatic products, bird's nests and other five categories of products no longer need to go through the entry-exit animal and plant quarantine approval procedures.

This will effectively simplify the import process of these products and reduce the time cost for enterprises.

Important Reminder: Exemption from approval does not mean exemption from compliance, and other access requirements (registration, certificates, etc.) must still be met.

Recommendations from Reach24H for Enterprises

For food enterprises that want to enter the Chinese market, adequate preparation before import is the core principle for opening up the Chinese market channel:

• Source Control: Strictly screen eligible countries and registered suppliers (check the catalog, check the registration number).

• Timely Filing: Complete the filing in a timely manner and fulfill the responsibility of qualification guarantee.

• Complete Documents: Ensure that each batch of goods is accompanied by authentic and valid official certificates, and the certificate information is 100% consistent with the goods and declaration data.

• Pay Attention to the Latest Policy Requirements: Pay special attention to changes in quarantine approval policies (such as the convenience brought by Announcement No. 158) and continuously track updates to customs regulations.

For more information and inquiries, please feel free to contact us at customer@reach24h.com.