27 October 2021
This Industry Advice Notice (IAN) is to provide updated information on the registration of food processing and storage facilities handling product for export to China, and product labelling requirements for food products exported to China.
- A recording of the Webinar held on 22 October 2021 (refer to IAN 2021-55) will be published through Have Your Say – China’s new requirements for imported food products.
- The online service for facilities to apply for recommendation for registration with the General Administration of Customs of the People’s Republic of China (GACC) will remain open for applications until the department submits its application to GACC on Thursday 28 October 2021, 5:00pm AEDT.
- Detailed advice on the issues of registration numbers and labelling requirements in provided below.
- We understand that fresh fruit packhouses and storage facilities do not need be registered as a food facility with GACC.
- We understand from the description provided by GACC that Decree 248 is not applicable to unprocessed wheat and barley.
Webinar (22 October 2021) recording to be published
On 22 October 2022, we held a webinar to provide food processing and storage facilities handling food exported to China more information on China’s new imported food requirements.
A recording of the webinar and our responses to questions raised about China’s new imported food requirements will be available through Have Your Say – China’s new requirements for imported food products.
Webinar registrants will receive an email once the recording has been published.
Correction to advice regarding eCommerce trade
For those who attended the webinar, we would like to make a correction regarding the relevance of China’s new imported food requirements on eCommerce.
At this stage we understand that the import and export of food through mail, express delivery, cross-border eCommerce retail, or carried by travellers, are not required to abide by China’s new requirements for facility registration and labelling.
Clarification to advice regarding bilingual (English/Chinese) language labelling requirements
For those who attended the webinar, we would like to clarify information regarding bilingual language labelling requirements.
At this stage, we understand that the bilingual language (English/Chinese) labelling requirements have only been confirmed for exported meat and seafood products. There is no clear advice on whether these requirements apply to other exported food commodities.
We will provide further information on labelling requirements when available.
Registration requirements for food processing and storage facilities handling product for export to China
There are three registration processes that may apply to food processing and storage facilities handling food for export to China.
The following information describes the processes for registration and labelling requirements that apply to food products, not including meat, dairy and seafood products.
1. Food processing and storage facilities handling products for export China that require department recommendation for registration with GACC
1.1 Closure of online service for applications and submission of information to GACC
- Further to IAN 2021-53 and 2021-55, the online service will remain open for applications until the department submits its recommendations to GACC on Thursday 28 October 2021, 5:00pm AEDT.
- Late submissions may encounter delays in registration and could disrupt trade.
- We understand GACC will use this information to publish approved lists of food processing and storage facilities on their website, however a specific timeframe on when this will occur has not yet been advised.
- Food processing and storage facilities that have not yet submitted an application through the online service will need to follow the process described in Section 1.3 of this notice.
1.2 Allocation of department issued registration numbers
- If your facility already has an existing departmental establishment number (ER number), this number will continue to be used for all food categories your facility handles for export to China that require departmental recommendation for registration.
- If your facility does not have an existing ER number, once your application has been processed, this will be issued by the department for your facility.
- If a business has multiple facilities in different locations, a unique number will be issued for each facility per location. This number will be used for all food categories your facility handles for exports to China that require departmental recommendation for registration.
1.3 Food processing and storage facilities that did not complete an application by 22 October 2021
- Food processing and storage facilities that did not complete an application by 22 October 2021, will need to register following the steps outlined in Article 8 of the ‘Regulations of the People’s Republic of China on the Registration and Administration of Overseas Producers of Imported Food (Decree 248)’ if they intend to export food products to China.
- An English translation of Decree 248 may be obtained from the United States Department of Agriculture, Global Agricultural Information Network reports China: Regulations on the Registration and Administration of Overseas Producers of Imported Food - Decree 248.
- We will issue advice on the registration process for food processing and storage facilities once GACC has issued advice on how these applications will be accepted and processed.
1.4 Labelling requirements
- In addition to the labelling requirements outlined in IAN 2021-53, we understand that GACC intends to enforce product labelling requirements for food imported into China on or after 1 January 2022.
- Further information on labelling requirements will be provided once ER numbers have been issued and registration information has been submitted to GACC.
2. Food processing and storage facilities handling products for export China that require self- registration with GACC
2.1 Self-registration requirements
- Self-registration with GACC is not required for the following products
- prescribed meat dairy and seafood products
- fresh fruit
- listed in Attachment 1 of IAN 2021-53.
- GACC has advised not to complete self-registration their ‘single window service system’ until after 1 November 2021.
- If you completed a self-registration prior to 1 November 2021, we recommend submitting another application after 1 November 2021.
- We will issue updated advice on application for self-registration through the GACC ‘single window system’ after 1 November 2021.
2.2 Labelling requirements
- We understand that either a GACC-issued registration number or the registration number issued by the exporting country must be included on the inner and outer packaging.
- Further information on labelling requirements will be provided after 1 November 2021.
Contact Export Listing for any enquiries.
A/g Assistant Secretary
Plant Export Operations Branch
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.