Date of issue: 13 October 2021
Date of effect: From 1 January 2022
Reference Number: MAA2021-40 (Dairy), MAA2021-21 (Seafood), MAA2021-15 (NPG)
Related: MAA2021-38 (Dairy), MAA2021-20 (Seafood), MAA2021-14 (NPG)
- Industries—Industry bodies – Dairy Australia, Dairy Export Industry Consultative Committee, Infant Nutrition Council and Seafood Export Consultative Committee, Export dairy and seafood establishments, Australian Food and Grocery Council and Australian Honey Bee Industry Council.
- Department of Agriculture, Water and the Environment —Central and Regional offices
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To provide detailed instructions for the registration of food processing and storage facilities handling product for export to China, and product labelling requirements for food products exported to China.
Summary of key points
- Further to Market Access Advices MAA2021-38 (dairy) and MAA2021-20 (seafood) and MAA2021-14 (non-prescribed goods), the Department of Agriculture, Water and the Environment is providing detailed instructions for the registration of food processing and storage facilities handling product for export to China, and product labelling requirements for food products exported to China.
- Australian food processing and storage facilities with a history of handling food exported to China since 1 January 2017, should read the information below and take appropriate action as required by specified timeframes.
1. Food processing and storage facilities handling only meat, dairy, and seafood products for export to China
1.1: Registration requirements
There are no changes to the existing registration and listing processes for meat, dairy and seafood processing and storage facilities. As such, no action is required for meat*, dairy** and seafood facilities which are currently listed for the export of these products by the General Administration of Customs of the People’s Republic of China (GACC). Please note that this also applies to:
- facilities which are listed by GACC, however are currently suspended.
- cold stores and processing establishments
* Meat processing and storage facilities already listed with GACC, who are exporting casings will need to notify the department as per the advice under ‘Food processing and storage facilities handling product for export to China that require department recommendation for registration with China’ (Section 2). Please refer to the definitions of casings in Attachment 1 before registering products.
** Under existing registration requirements storage facilities handling dairy products are not required to be registered or listed with GACC and this remains unchanged. These facilities are not required to complete registration under Section 2.
1.2: Labelling requirements
The information included on the inner label of product must be provided in both English and Chinese language. This applies to all product imported into China after 1 January 2022. Note that previous requirements allowed the option for either English or Chinese language to be used on inner labels.
With the exception of this change, existing labelling requirements for meat products align with the China’s new regulatory requirements.
There are significant labelling changes required to be made for ‘non- viable’ seafood products exported to China from 1 January 2022. These changes include:
- information included on the inner and outer label of product and must be provided in both English and Chinese language
- additional information required on both inner and outer labels is as follows;
- scientific name of species
- batch number (this could be a separate number of reflect production date)
- production methods (wild caught (seawater or freshwater) or aquaculture (seawater or freshwater) production)
- production area (ocean fishing area, freshwater fishing country or country/region, from which the aquaculture products are)
- name registration and address of all facilities involved in the production (including fishing and transport vessels and cold stores)
- Destination marked as People’s Republic of China
China’s new regulations do not specify any additional labeling requirements for dairy products. As such, existing labelling requirements for dairy products remain unchanged.
If you export other food products please refer to Section 2 and 3 below.
2. Food processing and storage facilities handling products for export to China that require department recommendation for registration with China
This applies to food processing facilities that carry out the final processing step for the following food categories, as well as storage facilities where product is subsequently handled prior to export to China (detailed descriptions available in Attachment 1):
- Casings1, eggs and egg products2, bee products, edible fats and oils, stuffed wheaten food, edible grains, milled grain products and malt, fresh-kept/preserved and dehydrated vegetables and dry beans, condiments and seasonings, nuts and seeds, dry fruits, unroasted coffee and cocoa beans, food for special dietary uses, health foods
GACC has provided the department with a list of products which have been identified as having historical trade since 1 January 2017 (Attachment 2). If your facility is handling a product for export to China which is not captured in this list, email firstname.lastname@example.org by 22 October 2021.
2.1 Applications required by 22 October 2021
Food processing and storage facilities handling these products for export to China need to submit an application to the department by 5:00 pm 22 October 2021 for the department to be able to recommend registration with GACC in line with new requirements. Late submissions may encounter delays in registration and could disrupt trade.
The department has established an online service for this application process. Food processing and storage facilities must complete and submit an application to the department, in order for the department to recommend their registration with GACC. Guidance on how to apply is at Attachment 3.
If you cannot access the online service, email email@example.com and request a form will be sent to you.
All food processing and storage facilities must be registered with China for all food categories they handle. For example, should your facility handle ‘stuffed wheaten food’ and ‘fresh-kept/preserved and dehydrated vegetables and dry beans’ for export to China, your application must include each applicable food category. Further, if your food processing and storage facility has multiple locations, all must be registered individually.
Once a facility has completed the online application, the department will issue an establishment number to those facilities that do not already have an existing departmental Establishment Number (also referred to as an ER number).
For food processing and storage facilities handling multiple products for export to China, your facility will be issued a single establishment number. This number must be used for all products the food processing and storage facility handles for export to China. If your business has multiple facilities, a unique establishment number will be issued for each facility (location).
For food processing and storage facilities that already have an existing departmental Establishment/ER Number, your existing number is to be used for newly registered products handled by your facility for export to China. You will be required to enter this number when completing the online registration process. For example, if a facility with an existing establishment number ‘000’ exports both meat and casings products to China. The existing ER number ‘000’ will be used in this case for the new casings registration.
2.2: Labelling requirements
Labels must be affixed to both the inner and outer packaging for all products listed above with the exception of foods for special dietary uses and health foods. For these products, adhesive product labels will not be accepted and labels must be printed on packaging.
GACC’s new requirements specify that exported food must include on the inner and outer packaging, either a GACC-issued registration number or the registration number issued by the exporting country (departmental Establishment/ER Number). The department understands that this also includes sales packaging. The department will provide further advice on how facilities can meet this requirement following the issuing of Establishment/ER Numbers after applications are processed.
3. Food processing and storage facilities handling product for export to China that require self-registration with GACC
Food establishments (and storage facilities) for all foods that are not covered in section 1 or 2 need to self-register or register through their importer or agent.
As an amendment to MAA2021-14 (NPG), the department understands that although the GACC established ‘single window service system’ is currently open for use, GACC has since advised that establishments requiring self-registration should not complete this process until after 1 November 2021.
For establishments that have already completed registration through the ‘single window service system’, the department is currently seeking advice from GACC on whether the registration process will need to be completed again following 1 November 2021. Revised instructions on how to complete this process will be provided to establishments in early November 2021.
4. Further information
Contact firstname.lastname@example.org if you have any queries.
1 Inedible unprocessed intestines/green runners are not considered casings products and are therefore not required to be registered with GACC. Before registering casings products, please refer to Attachment 1 for a detailed product definition to determine if your product requires registration.
2 Australia does not have access for egg and egg products for export to China.
The information provided in this advice is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive. The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice. Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.