Since January 1st, 2022, all overseas food-producing, processing, and storage companies must comply with the new registration regulations according to the General Administration of Customs in China (GACC) regarding exporting food products to China.
All foreign companies who currently export food to China will have to go through two procedures; high-risk food producers will have to register with China Customs via foreign authorities. Any other food producers must submit their registration applications directly to Chinese Customs without using a third party. Therefore, understanding the new 2022 Customs Regulations is vital for the food importing and exporting industry.
As a premium Quality Assurance party with rich experience in the Chinese and Global markets, HQTS Group has recently organised an in-depth webinar about the new regulations to support your exporting business to China.
Trends and opportunities
Meat consumption is on the rise, and pork is the preferred meat of choice, around 40.3 million metric tons of pork were eaten in 2020. The increase in exporting and importing meat is expected to continue growing in China as disposable incomes increase and the middle class continues to expand. The consumption of beef and chicken is also expected to rise more than in any other country outside the USA.
However, with plant-based alternatives becoming increasingly popular, this could decrease the meat-eating demands. China’s ‘free-from-meat’ market has grown 33.5 per cent since 2015, and it was worth $9.7 billion in 2018 and is predicted to be worth around $11.9 billion by 2023. As livestock farming produces 20-50 per cent of all man-made greenhouse gases, finding alternative protein sources is crucial to meet these targets. More plant-based options could all be part of China’s plan to curb carbon emissions. Furthermore, the Chinese embrace healthier lifestyles and rapidly modernise their society.
Significant changes of new regulations
The GACC updated its regulations on food imports on January 1st, 2022, and there are 11 significant changes importers and exporters need to be aware of:
- The scope of registration has been expanded – the old regulation only required companies who produced products for registration. This included; meat, aquatic, dairy, birds’ nest, and bee products. However, the new regulation requires registration for companies who not only produce but also process and store these products when exporting to China.
- The registration method – before, a foreign company that produced imported food had to be registered by the competent authority of the country where the company is located. In the new regulation, the registration method is determined by the product category. Products outside the high-risk product list can choose to apply by themselves or get support from an agency, such as HQTS.
- The registration application materials – after completing a food safety evaluation, it is no longer required to provide materials related to animal and plant epidemics, veterinary hygiene, public health, food production companies’ registration management, health requirements, and the layout and personnel situation of the competent authority. However, the audit report provided by the competent authority and identity documents of the companies is still required.
- Innovate registration approval methods – the GACC shall organise relevant experts or assign agents to review the materials and form an assessment team. This team should have at least two members, but the assessment form can now be completed using materials, video inspection or on-site inspections, or all of the above.
- Clarify registration number management – the old regulation stated that the food production company which gained the registration should mark the registration number on the outer packaging of the food. In the new regulation, the registered company must mark both the food’s internal and external packaging with the registration number in China or the registration number approved by the competent authority.
- Clarify the requirements for dietary supplements – the label for dietary supplements must be printed in Chinese on the final sales packaging.
- The validity period of registration – the registration validity and the renewal of registration has now been extended to 5 years, the same as the validity of the Chinese domestic food production license.
- The application materials – proof materials related to the renewal must be provided, and GACC must approve the registration renewal. If the renewal is related to the change of production site, the legal representative, or the registration number granted by the country, the registration should be reapplied, and the previous registration number in China will automatically become invalid.
- The validity extension application – an application form and a statement will be needed for the validity extension application, and the application must be submitted to GACC 3-6 months before the expiration date.
- Clarify the responsibilities – only registered companies who got caught out as unqualified during the review were supervised to fulfil corrective actions. The new regulation states that the competent authority must take the initiative to suspend their exporting to China when any problems are found and take corrective actions immediately.
- Reduce the scope of competent authorities – the competent authorities in the old regulations include the official departments, officially authorised institutions, and industry organisations in the countries where the food production companies are located. However, the new regulations have changed so that the competent authority only refers to the official department responsible for the safety and health supervision of the food production company in the country where it is located.