On April 12, 2021, China’s General Administration of Customs issued Administrative Measures for the Registration of Foreign Manufacturers of Imported Food, which will take effect on January 1, 2022.[1]  These new Measures provide more detailed guidance and more stringent requirements on the registration of foreign food manufacturers.

The new Measures provide that all foreign food manufacturers must register with the China General Customs Administration before the foods they produce may be imported into China.  Foreign manufacturers of eighteen categories of food (including meat products, dairy products, and health foods) may only obtain this registration after the competent authority of the country where the manufacturer is located inspects the manufacturer and recommends registration.  The competent authority must be a government department; industry organizations and agencies authorized by government will no longer qualify.  Manufacturers of other foods, on the other hand, may apply for registration without first obtaining a recommendation.

The Measures introduce new methods for conducting application evaluations and inspections before approving a registration, including documentary inspection, video inspection, and on-site inspection.  The validity period of a registration has also been extended from four to five years.

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Contributors for the China Food Law and Regulation blog:

John Balzano, Julia Post, Muyun Hu, Annie Wang, and Audrey Zhi

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[1] See http://www.customs.gov.cn/customs/302249/2480148/3619591/index.html.

Photo of Muyun Hu Muyun Hu

Muyun Hu advises multinational and Chinese companies on a range of regulatory, policy, transactional, and litigation matters. Her work focuses on the life science industry, particularly with regard to food, drug, medical device, cosmetic, and other regulated products.