China is set to revise its registration requirements for overseas food manufacturers exporting to the Chinese market. The General Administration of Customs (GAC) has proposed amendments to the Regulations on Registration and Administration of Overseas Manufacturers of Imported Food (GAC Decree 248), inviting public comments until February 2025.
New Registration System for Foreign Food Manufacturers
China first introduced GAC Decree 248 in 2021, requiring all overseas food manufacturers to register with GAC before exporting to China. After three years of implementation, the Chinese authorities are now refining the framework to improve efficiency and address industry challenges.
One of the key changes in the draft amendment is the introduction of a system recognition pathway. This allows the regulatory authorities of exporting countries to gain official recognition from GAC. Once recognized, these authorities can submit lists of approved manufacturers, who will then receive official registration numbers without needing to apply individually. This could streamline the registration process for businesses exporting food to China.
Changes in Registration Pathways
Under the current rules, GAC Decree 248 classifies imported food based on risk levels, with separate pathways for high-risk foods (such as meat, dairy, and seafood) and other food products. The proposed amendments shift the focus to national-level classification, placing more responsibility on exporting country authorities to oversee food manufacturers.
For countries without GAC recognition, manufacturers will need to apply for registration individually or through an agent. Requirements will vary depending on the food category. Businesses dealing in high-risk foods listed in the Catalogue of Foods that Require Official Recommendation Registration Letters must provide official inspection reports and recommendation letters from their national regulatory body.
Updated Food Categories & Regulatory Exemptions
The draft revision also updates the Catalogue of High-Risk Foods, outlining which products require government-backed registration. Notably, several food types, including health foods, dietary supplements, special dietary foods, unroasted coffee beans, and edible oils, may no longer require government-recommended registration. This change could significantly reduce compliance costs and speed up market entry for certain businesses.
GAC has also removed mandatory re-registration requirements for certain administrative changes, such as legal representative changes or national registration number updates. Re-registration will only be required for significant modifications affecting food safety and sanitation management, such as relocating production facilities.
Additionally, the revised regulations eliminate the requirement for overseas manufacturers to renew their registrations three to six months before expiration. Some food categories will also be exempt from facility registration, including:
Food sent by mail or express delivery
Cross-border e-commerce retail food items
Food carried by travelers
Sample products
Food additive manufacturers exporting to China remain exempt from the facility registration requirements, maintaining the existing rules under GAC Decree 248.
Impact on Foreign Food Manufacturers Exporting to China
These regulatory updates highlight China’s efforts to enhance food safety oversight while simplifying administrative procedures for foreign food manufacturers. However, uncertainties remain regarding how the new system recognition pathway will integrate with the existing registration framework.
One key question is whether companies already registered under GAC Decree 248 will need to coordinate with their national authorities to be included in the new system. If not clarified, this could pose challenges for food exporters navigating the transition.
Next Steps for Food Exporters
Overseas food manufacturers should closely monitor these regulatory changes and assess how they may impact food export requirements, registration procedures, and market access in China. Companies are encouraged to engage with their national authorities to ensure compliance with the revised framework and avoid potential trade disruptions.
These amendments could present new opportunities for foreign food businesses looking to enter or expand in the Chinese market, provided they stay informed and adapt to the evolving regulatory landscape.
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