As the world’s largest imported food market, China imported totally 38 billion US dollars food products from187 countries in 2016.
The growing China market has attracted a lot of interest from different countries over the world. Meanwhile China government has, over the last years, developed a tougher and tougher food regulation regime to regulate the market and ensure food safety.
Due to various challenges (languages, resources, information accessibility etc.), foreign SMEs learned a lot lessons and experienced big losses due to non-compliance with Chinese regulations.
Actually majority of these losses due non-compliance can be easily prevented if SMEs have reliable regulatory information in hand.
As a leading Chinese food regulation consulting company, FoodMate developed “Compliance Excellence” information service product for foreign SMEs with target to minimize your losses due regulatory non-compliance by assessing reliable and tailor made regulatory information.
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FoodMate “Compliance Excellence” to reduce your losses due non-compliance with China food regulation
1. 1
FoodMate “Compliance Excellence” to reduce your
losses due non-compliance with China food regulation
FoodMate China –Business development manager
2017.9
Rong Liu (liurong@foodmate.net)
2. • As the world’s largest imported food market, China imported totally 38 billion US
dollars food products from187 countries in 2016.
• The growing China market has attracted a lot of interest from different countries
over the world. Meanwhile China government has, over the last years, developed a
tougher and tougher food regulation regime to regulate the market and ensure food
safety.
• Due to various challenges (languages, resources, information accessibility etc.),
foreign SMEs learned a lot lessons and experienced big losses due to non-
compliance with Chinese regulations.
• Actually majority of these losses due non-compliance can be easily prevented if
SMEs have reliable regulatory information in hand.
• As a leading Chinese food regulation consulting company, FoodMate developed
“Compliance Excellence” information service product for foreign SMEs with target
to minimize your losses due regulatory non-compliance by assessing reliable and
tailor made regulatory information.
Introduction
3. • Food imported to China and losses due regulatory non-compliance
• China food regulation and supervision system for imported food
• Challenges for oversea food enterprises to reduce losses due
regulatory non-compliance
• FoodMate “Compliance Excellence” service to reduce your losses
Agenda
3
5. 5
Imported food rejected
by CIQ in 2016
Oversea food
manufacturers with
CIQ’s non-compliance
record in 2016
Source: AQSIQ and CFDA
Oversea food
manufacturers in CIQ’S
warning list till 2017
China - world’ s largest imported food market
Growing import refusal and non-compliance inspected on market
57
million
US dollars
1000+
manufacturers
203
manufacturers
During importing
(Inspection by CIQ)
Compliance rate
out of all inspected
batches
96.8%
In market (after importing)*
(Inspection by CFDA and local FDA )
Importing refusal and/or on market inspection non-compliance would lead to
suspended or canceled admission to China.
755
tons
Pulled off from shelves
and recalled from
market
Non-compliance
records from
manufacturers /
distributors / importers
9264
pieces
• *Combined data of domestically produced food and imported food.
• CIQ: China inspection and Quarantine, CFDA: China food and drug administration, FDA: food and drug administration
6. 6
Regulatory non-compliance due improper import feasibility
study topped the import refusal reasons
Top 10 rejected reasons accounting for 98.2% of all refusal in 2016
Source: AQSIQ
Additives, label, license and certification related non-compliance are largely NOT
related with product quality or quality itself is good. And losses due these non-
compliances reasons can be easily prevented by proper feasibility study and
compliance control.
Pure regulatory
non—compliance
0.00% 10.00% 20.00% 30.00%
GMO
Illegal importation
Package unqualified
Contaminants
Microbial contamination
Quality incompliance
Certification not match the goods
Unqualified license
Unqualified label
Additives incompliance
7. 7
5 containers of French Champaign rejected by China CIQ due food additive non-compliance
• One French exporting company exported 5 containers of Champaign with gold
flakes 22.5K to China Shenzhen port in 2016.
• It was rejected by Shenzhen CIQ during the arrival inspection due it is NOT allowed
to add gold flakes 22.5K in Champaign according to China food regulation.
• With the import refusal, the 5 containers were returned to France.
• According to EU and Japan regulation, it is allowed to use gold as food additive.
• In 2014, China national food safety risk assessment center has released exposure draft
about gold used as food additive in wine. It provoked lots of concerns from the public,
therefore it was decided by the central regulation office that it is NOT allowed to use
gold as food additive.
Reliable information
Take away for oversea food enterprises
• Regulatory compliance feasibility study is a prerequisite to import food product
(especially during the initial importing) to China (or other countries).
• Do NOT assume China regulation is the same with EU/US/your exporting country
Case study: losses due regulatory non-compliance
Background
8. 8
Töpfer (infant formula) export license to China suspended by China CNCA
Case study: losses due regulatory non-compliance
• Töpfer, a leading organic formula in Europe, awarded as one of TOP 10 imported organic infant
formula brands in China market for several years..
• In May 2016, 4 batches of Töpfer formula was inspected by FDA of Heilongjiang province and
result showed that DHA/ARA content was not complied with China standards. Töpfer was
requested to recall the product and take corrective actions.
• In May 2016, Töpfer infant formula was suspended for imports to China by CNCA.
• China regulation (GB10765 & GB10767, GB13432, and GB/T 5413.27-1997) should be all
complied for labeling/claim, and inspection of DHA in infant formulas
Reliable information
Take away for oversea food enterprises
• After CIQ acceptance during importing, imported food will still be inspected by China
CFDA or local FDA. Non-compliance inspected by CFDA or local FDA could lead to pull
off from shelf/cancellation of the import license.
Source: http://www.hljda.gov.cn/spcjxx/7845.jhtml
Background
9. • Food imported to China and losses due regulatory non-compliance
• China food regulation and supervision system for imported food
• Challenges for oversea food enterprises to reduce losses due
regulatory non-compliance
• FoodMate “Compliance Excellence” service to reduce your losses
Agenda
9
10. China food regulation system and authorities
Note:
CFDA: State Administration of food and Drug Administration
AQSIQ: General Administration of Quality Supervision, Inspection
and Quarantine of the people’s republic of China
MIIT: Ministry of Industry and Information Technology of the
People's Republic China
NHFPC: National Health and Family Planning Commission
MOA: Ministry of Agriculture
11. CNCA
AQSIQ
Certification and Accreditation
Administration of China
Responsibility:Imported food
manufacturer registration
General Administration of Quality
Supervision Inspection and Quarantine
of China
Responsibility:Imported /exported food
supervision, inspection and quarantine
CFDA
China Food and Drug Administration
Responsibility:Product registration,
formula registration, domestic
distribution supervision
China food regulation structure for imported food
FSMP: Formulized food for special medical purpose
Food categories
General
food
Special
food
Seafood/dairy/
meat, cubilose
etc. (totally 8)
Manufacturer
registration by CNCA
Others
Health food
Infant formula
FSMP
Registration or filing
by CFDA
Manufacturer
registration by CNCA,
Formula registration
by CFDA
Registration requirement
Manufacturer
registration by CNCA,
Formula registration
by CFDA
Manufacturer
registration not needed
All food imported to China has to comply with
China food standards. Manufacturer and/or
product formula registration is required for
defined food categories
The Regulators for Imported Food
covers the control before, during
and after the importing
12. 12
Project set up Drafting Reviewing Approval / Release
Take away for oversea food companies:
- Compliance with latest version of all related regulations
- Take actions in front of update and be proactive to take action for the update
Frequent regulation update in recent years
A process is defined to release new regulation standards or revise existing standards.
All companies/institutes/individuals are welcomed to give input during the drafting and reviewing stage.
50
148
61
44
0
20
40
60
80
100
120
140
160
Food
products
standards
Food
additives
standards
Detection
method
standars
Food
related
standards
164 151
413
159
0
50
100
150
200
250
300
350
400
450
General
standards
Food
products
standards
Detection
method
standards
Food
related
standards
Standards released in 2015 and
implemented in 2016
Standards released in 2016 and
to be implemented in 2017
1 2 3 4
13. • Food imported to China and losses due regulatory non-compliance
• China food regulation and supervision system for imported food
• Challenges for oversea food enterprises to reduce losses due
regulatory non-compliance
• FoodMate “Compliance Excellence” service to reduce your losses
Agenda
13
14. End to End compliance should be in place to prevent losses
Failure in one of the items could lead to import refusal or on market refusal
China regulation system for imported food—end to end supervision to ensure food safety
15. Maturity mapping of regulatory compliance
Higher maturity level leading to lower losses for the business
15
- Have general understanding that there are Chinese policies, laws regulations,
supervision systems to be followed/complied for imported food
- Insufficient deep dive study on all regulations related with target productLevel 1
- Familiar with most regulations related with target product
- Able to identify general compliance gaps, but risks learned case by caseLevel 2
- Deep understanding on all end to end regulations related with target product
- Compliance gap can be mostly identified and key risks can be mitigated
- Assess to update on all regulations/safety event and quick counter measures can
be prepared for the updated regulation
Level 3
- Mastering on all the regulations related with target product
- Compliance gap can be thoroughly identified and majority of risks mitigated
- Engaged in regulation update draft process and proactively voice out constrains to
implement the updated/new regulations before it is issued, hence co-develop the
new/updated regulation with the authorities
Level 4
Compliancematuritylevel
Lossesduenon-compliance
FoodMate survey showed that big 85.6% of SMEs (who export food to China) are
located in level 1 & 2 and international food giants are more located in level 3 & 4.
Risk: Business exposed to compliance gap and various risks
Risk: Unable to track latest regulation update/trend and develop the countermeasures
LowHigh
HighLow
16. Export
manager
Local
distributor
Oversea
headquarter China market
Challenges for SMEs to reach higher compliance maturity and
lower losses
SENSE OF IMPORTANCE – regulatory compliance is down prioritized
No in-house expert or reliable partner on China regulation (due cost or availability
reason) and export managers are acting as regulation expert on top of huge commercial
agendas
Passively receiving unreliable information (fragmented/inaccurate/untimely) from
different channels
:Product flow : Regulatory information flow
17. Export manager
……
Challenges for export managers to get
timely and reliable take away
Language and culture barriers
Can only get part of the story from free
online newsletters
The official government announcements
looks ambiguous
Mainly rely on China distributor to get the
“take home” message, however the
distributor may also under estimated the
regulatory impact
Export managers getting
information from various channels
Why export managers failed to get timely and
reliable “take home” message
Take away:
A reliable & professional China regulatory
partner is needed to get reliable and clear “take
home” message with the right cost
18. • Food imported to China and losses due regulatory non-compliance
• China food regulation and supervision system for imported food
• Challenges for oversea food enterprises to reduce losses due
regulatory non-compliance
• FoodMate “Compliance Excellence” service to reduce your losses
Agenda
18
19. Our Company
• Leading food industry consulting company in China established since 2001
• 1.2 million registered members
• Headquartered in China with business footprint all over the world
Our mission
• Provide end to end regulatory services & solutions for our clients entering China market
• Minimize our clients' food regulation risks and maximize clients’ business performance in China
Our key client
• Chinese companies and institutes in food industry
• Small & medium-sized foreign companies in food industry
FoodMate China introduction
Our team
• 150 internal experts on food industry regulations covering all China food categories
• Team closely collaborating with China CFDA, institutes and universities
20. FoodMate “ComEx” to provide you reliable regulatory
information and clear take home message
“ComEx” (Compliance Excellence) is an information service product developed for foreign
SMEs to reduce losses of China exporting business due to regulatory non-compliance. It
subjects to provide reliable regulatory information & its clear take away for SMEs, so that
SMEs can proactively take actions to prevent any losses.
Step by step process guideline on exporting target product to China
Training of all target product related Chinese regulations and standards
Summary of main import refusal reasons of target product and counter measures
measures
Improve compliance maturity from Level 1 to Level 2
Summary and deep dive training of all target product related regulations
Monthly monitoring on latest regulation update /expert interpretation
/counter measures/early alerting
Recommend timely countermeasures in front of regulation update
Improve compliance maturity from Level 2 to Level 3
Improve compliance maturity from Level 3 to Level 4
Support client to master all the regulations related with target product
Support client to be engaged in regulations and standards draft process
Support the communication with Chinese government
“ComEx” service is tailor made for your product and your current compliance maturity level*
* compliance maturity level 1- 4 description can be found in slide 15
21. “ComEx” to provide tailor made, reliable, comprehensive
information for you with very low cost
21
Reliable
Tailor
Made
• Messages always
interpreted for client
to take home
• With 150 internal
regulation experts as
well as a large
external expert team
• Close connection with
CFDA 、NHFPC、
MOA、AQSIQ;
• Based on your product
category
• Based on your current
compliance maturity
Low
cost
Compreh
ensive
• We share our scale
effect to clients
• Significant cost saving
comparing with clients’
common practices
today
• Release export
manager’s time from
regulatory to
commercial agendas
• End to end process
related food
regulation
• From China market
survey, sampling
from CIQ, CFDA to
after sales service
related information
consulting
22. • Products category
• Regulation gap mapping
• Compliance record
• Current market in China
• Align on future state
expectations
• FoodMate to recommend
plans to close compliance
gap based on current state
• Agree on service scope,
approach and frequency
• Contracting
• Start the service
How can we start to contribute to your journey in China
Clients’ current state
assessment
Align on future state
expectation
Service agreement and
contracting
2 31
23. ComEx - Case sharing
Improve regulatory compliance maturity from Level 1 to 2
23
Product category: Wine
China wine market overview
Step by step process guideline to export wine to China market
All China wine related regulations and standards training
Main import refusal reasons of wine
* compliance maturity level 1- 4 description can be found in slide 15
24. ComEx - Case sharing
Improve regulatory compliance maturity from Level 2 to 3
24
Product category: Infant formula
China infant formula market latest overview
Deep dive training on all infant formula related regulations including
products/labeling/detection/ingredients etc.
Main import refusal reasons, non compliance reasons during on market inspections
Regulation trending
Monthly monitoring on latest regulation update, expert interpretation and warning alerting
Recommend actions in front of regulation update
* compliance maturity level 1- 4 description can be found in slide 15
25. 25
Product category: Novel food
China novel food latest overview & insight
Training of novel food registration in China
Support to communicate with government and pre-review
Support client to be engaged in regulations and standards draft process
ComEx - Case sharing
Improve regulatory compliance maturity from Level 3 to 4
* compliance maturity level 1- 4 description can be found in slide 15
26. Contact us
Your Reliable Food Regulation Service Provider
26
China Office
Beijing
Address: Floor 9, Tower A, Linglongtiandi
Building, No. 160 North Xisihuan Road, Haidian
District, Beijing
Yantai
Address: West area, Donghe Technology Park,
No. 229 Tongs South Road, Zhifu District, Yantai
City, Shandong Province
EU office
Address:Churerstrasse 92i, CH-8808,
Pfaeffikon SZ, Switzerland
Phone: +41 784034643
E-mail: :liurong@foodmate.net
Food regulatory and safety
monitoring clients in China