This document provides an overview of China's food import regulations and procedures. It discusses China's regulatory framework and the various government bodies involved in food regulation. It then outlines the key steps involved in the importation process, including customs registration, AQSIQ filing, CIQ inspection, and post-import monitoring requirements. It also discusses additional approvals needed for special types of foods, such as new food products, foods with health claims, and foods for special dietary uses. Approvals for new foods involve toxicology testing and demonstration of prior safe use to obtain approval.

1. Remove the regulatory barriers – import food to
China
1
Laura Wang
Food Regulatory Services Division
laura.wang@cn.reach24h.com
January, 2016, Israel

2. Agenda
2
Regulatory background and framework
Importation procedures
Additional approvals – special types of foods
2
3
1

3. Agenda
3
Regulatory background and framework
Importation procedures
Additional approvals – special types of foods
2
3
1

4. www.reach24h.com | www.Chemlinked.com
REACH24H
Consulting Group
Laws
Regulations
National Standards/
Government
Announcements
Local Regulations
Level 3
National Standards
e.g. GB xxx or GB/T xxx *
Government Announcement
e.g. Newly approved food additives
Level 1
Legislated by National Peoples congress
e.g. Food Safety Law 2015
Level 2
Legislated by the departments of State Council (General rules)
e.g. Administrative measures for inspection & supervision for
imported & exported dairy products
Level 4
Government of a province / big city
e.g. Administration Method
China Food Regulation Structure

5. Example of Regulatory Framework
5
Food Safety Law 2015: Article 97 Imported pre-packaged food and food additive shall
have Chinese labels. If instruction is required by laws or regulations, the instruction
in Chinese shall be provided. Labels and instructions shall comply with this Law and
provisions of other laws, regulations and food safety standards; the instructions shall
indicate county of origin, Chinese domestic agent's name, and contact
The Measure of Import and Export Food
Safety Management (2012)
GB 7718 – 2011
National Food Safety
Standard General
Standard for the
Labeling of
Prepackaged Foods
GB 28050 – 2011
National Food Safety
Standard General
Rules for Nutrition
Labeling of
Prepackaged Foods
Imported and exported food and
cosmetic label review regulation (2006)
GB13432 – 2013
National Food Safety
Standard Labelling of
Prepackaged Foods
for Special Dietary
Uses
…

6. Government Bodies
6
State Council of
PRC
CFDA
National Health & Family
Planning Commission
(NHFPC)
General Administration of
Quality Supervision,
Inspection and Quarantine
(AQSIQ)
Local CIQ (China
Inspection and
Quarantine)
The Certification and
Accreditation
Administration of China
(CNCA)
Supervise food market
in China
Supervision of
imports and exports
Accreditation &
Inspection
Formulate National
standards &
Registration

7. Regulatory historical timeline
80-90’s 2006-2009 2010-2014 now
• Food Hygiene
Law(1995)
•Food additives
Standards(1996)
Food labelling
standard(1994)
•Rudimentary
Product
Standards
•Food Safety
Law(2009)
•New Food
Safety Law(2015)
•Product
standards cover
most food
categories
•New food
additives
standards
(2014)
•Food labelling
standards(2011)
Melamine
scandals

8. Food Safety Law 2015
8
Chapter 6 Food Import and Export
• Article 92- Comply with National Food safety
Standards and subject to Inspection by CIQ & issue
quality certificate.
• Article 96 – AQSIQ importer/exporter Filling
• Article 97 – Must have Chinese Label
• Article 98- importer establish sales record

9. Agenda
9
Regulatory background and framework
Importation procedures
Additional approvals – special types of foods
2
3
1

10. Some facts
• Total 3134 non-compliant
• 1156 border return, 1967 destroyed, 2 other
cases
Border return
37%
Destroyed
63%
Others
0%
Data source: AQSIQ
Date: From Nov 2014 to
October 2015

11. Top 10 countries/regions
0
100
200
300
400
500
600
700
800
900
1000
Taiwan Korea Japan America Malaysia Italy Germany Tailand Spain France Other 64
nations
740
209 201 196 194
148 127 126 123 109
961

12. Top 10 categories
0
100
200
300
400
500
600
700
800
900
19 21 22 20 04 17 03 18 16 09 others
888
689
454
270
174 163
119 97
72 58
150
HS Code HS Code Notes Non-compliant batches
03 Fish and crustaceans, molluscs and other aquatic invertebrates 119
04 Dairy produce; birds’ eggs; natural honey; edible products of animal
origin, not elsewhere specified or included
174
09 Coffee, tea, mate and spices 72
16 Preparations of meat, of fish or of crustaceans, molluscs or other
aquatic invertebrates
58
17 Sugars and sugar confectionery 163
18 Cocoa and cocoa preparations 97
19 Preparations of cereals, flour, starch or milk; pastrycooks’ products 888
20 Preparations of vegetables, fruit, nuts or other parts of plants 270
21 Miscellaneous edible preparations 689
22 Beverages, spirits and vinegar 454

13. Top 10 Non-compliant reasons
0
100
200
300
400
500
600
599
542
518
309 293
262
171
135
305

14. Importation procedure (1)
Importer &
Exporter filing
Prepare
shipping
Start
clearance
after the
cargo arrives
Switch bills with
shipping agency
CIQ
Inspection!!!

15. Importation procedure (2)
Transport cargo to customs
bounded warehouse after
declaration
Transport cargo to CIQ
CIQ
inspection:
documents
verification
Label filing Issue label
filing
number
Issue Customs
Clearance of
Entry
Commodities
Customs
clearance
(pay tax)
Customs
release
Issue Frontier
Ports Hygiene
License
CIQ inspection
& quarantine
Distribution

16. Before Export CIQ Inspection Distribution
Products compliant with
China law & regulations
CIQ & Customs and
Clearance
Distribute products1 2 3
 Overseas factory registration
 Product registration
 Exporter Filling
 Product Compliance
 Ingredient & Additive
Compliance
 Chinese Labelling
 Food Contact Material
compliance
 CIQ Inspection
 Inspection & Quarantine
Certificate
 Label Filling
 Self-Declaration report
 Third party testing report
 Random Sampling
 Pay Tariff
 Recall system
 Importer to record all sales
 CFDA conduct random market
inspection
 Bounty Hunters
3 Steps: importation procedures

17. Before Export
Products compliant with
China law & regulations
1
 Overseas factory registration
 Product registration
 Exporter Filling
 Product Compliance
 Ingredient & Additive
Compliance
 Chinese Labelling
 Food Contact Material
compliance
Before export
Key question: whether
this product can be
imported to China?

18. Product Category
Raw materials
Food additives
Food contact materials

19. Category
• Comply with general GB standard
• Find the product GB national standard!
An example of product standard
• If there is no corresponding standard
– Option 1: Find the general category
– Option 2: Register own standard (not yet known
how to do)
– Popcorn, sweets and nuts example
• If any special registration needed (talk later)

20. National Standards
General Standards
 GB 7718-2011 general standards about labeling of
prepackaged food
 GB 13432-2011 general standards about labeling of
prepackaged food for special use
 GB 28050-2011 general standards about nutrition labeling
of prepackaged food
 GB 2760-2014 usage standards of food additives
 GB 14880-2012 usage standards of food nutrition fortifier
 GB 2761-2011 maximum limits of mycotoxins in foods
Product Standards
 GB 10765-2010 Infant formula
 GB 9678.2 Chocolate
 GB 2707-2005 Hygienic Standard for Fresh (Frozen) Meat of
Livestock

21. Raw materials
• If specially origin in Israel – be cautious
• If not sure, confirm with business partners or
consulting firms
• New raw materials? – new food raw materials
registration (talk later)

22. Food additives
• GB 2760 – 2014 is the national standard for
food additives
• Prepare during R&D
• Familiar with carry over principle and anti-
carry over principle

23. Food Contact Materials
• Ask the supplier to check with Chinese FCM
regulations

24. PartnerinChina Competent ability
Qualified certificates

25. Authorised importers?
You either import them yourself (with your own company),
or you use a qualified Chinese importer.
To become a foreign trade operator (importer), a foreign
company needs to establish a Foreign Invested Enterprise
(FIE) in China first.

26. Customs registration
Food can enter the territory of China only after the importer has declared to Chinese
customs.
Documents required for customs registration are as follows:
(1) Business licence;
(2) Registration form;
(3) Registration form of company applying for customs declaration and registration form
of managing staff of company applying for customs declaration;
(4) Tax registration certificate;
(5) Bank account;
(6) Customs declaration special seal;
(7) Other documents required for the registration.
Customs Registration
Only when the importer has obtained a registration code (10 digits) can they declare
their goods to Chinese customs.

27. Documentation AQSIQ Filing
Testing reports
Hygienic form

28. AQSIQ filing
Administrative Provisions on Filing of Importers and Exporters of Imported Foods
(AQSIQ Order No.55-2012)
Source: http://ire.eciq.cn/
28

29. Testing reports
• For the first time imported food, a testing
report shall be provided
• Requirements:
– Recent
– No requirements on the labs
– Ensure the nutritional values are close to the
nutritional table

30. Hygienic forms/
Official Inspection & Quarantine Certificate
• Not necessary for each category but
requested by specific regulations
• Who issued this? Food safety related authority
Eg. UK – The department of Environment,
Food & Rural Affects
New Zealand – the Ministry of Primary
Industry
• Different forms agreed with China authority

31. CIQ & Customs and
Clearance
2
 CIQ Inspection
 Inspection & Quarantine
Certificate
 Label Filling
 Self-Declaration report
 Testing report
 Random Sampling
 Pay Tariff
During importation
CIQ Inspection
Key issue: understand
the local policy of CIQ

32. Treat every province as a Country

33. What do we see?

34. What CIQ see’s?
Labeling
GB 7718-
2011
Food contact material
GB 9685 Food additives
GB 2760
Testing report
Contaminants &
microorganism
limitations
GB 9678.2 Chocolate
Nutritional
claims
GB 14880

35. Importation procedure (2)
Transport cargo to customs
bounded warehouse after
declaration
Transport cargo to CIQ
CIQ
inspection:
documents
verification
Label filing Issue label
filing
number
Issue Customs
Clearance of
Entry
Commodities
Customs
clearance
(pay tax)
Customs
release
Issue Frontier
Ports Hygiene
License
CIQ inspection
& quarantine
Distribution
Prepare documents in
advance

36. Check-list
 Certificate of Origin
 Inspection and Quarantine Certificate (Local CIQ)
 Full Testing Report
 Declaration Form
 Power of Attorney
 Packing List
 Bills of Lading
 Contract
 Invoice
 Business License
 Original Label Samples
 Translated Label Samples
 Chinese Labels
CIQ Inspection

37. 37
Inspection highlights
• Testing of samples – GB items and nutritional value
• Label Filling (Pre-packaged foods have to be labelled in Chinese)
 local CIQ inspection and quarantine passes: issue Inspection and
Quarantine Certificate
X Non-compliance
• Black-listed products will have to be returned or destroyed.
• Minor non-compliances such as incompliant food label then it can be adjusted
and reprinted. (not affecting the food safety and quality)
CIQ Inspection

38. CIQ Label filing
1. After the samples have been inspected and are
deemed acceptable
2. Providing the original label and its Chinese translation
together with a sample of the Chinese label & other
required documents to CIQ for label filing.
3. In general this will take 3-5 working days, depending
on which Chinese port.

39. A compliant Chinese label
Product name
Net volume
Country of origin
Nutritional table
Storage condition
Production date
and shelf life
Distributor/Importer information

40. A compliant Chinese label
FAQs
• Q: Whether it can include foreign languages?
A: Yes, as long as they are not bigger than
Chinese
• Q: How to label the date of production and shelf
life?
A: Could print the exact date or say “see XX point
of the package”
• Q: Shall the allergy information be printed?
A: It is not mandatorily requested by the
regulations but if the allergic information is
provided, sometimes corresponding testing reports
should be provided.

41. 3
Post export
Key issue: entering
China does not mean
the end
Distribution
 Recall system
 Importer to record all sales
 CFDA conduct random market
inspection
 Bounty Hunters/professional
fake fighters
3 Distribute products

42. 42
• Records: Food importers shall maintain entry & distribution
records of products for at least two years.
• AQSIQ established credit rating system to manage manufacturers,
exporters and importers.
• Bounty-hunters/professional fake fighters
• Food recalls system for food safety issues
• CFDA Market Inspection
CIQ Declaration Procedure key points
Post-inspection:

43. 1. What standards does my product have to comply
with?
2. What to be noted if allergic information is printed
on the Chinese labels?
3. If CFDA found the unqualified imported food, what
possible actions they might take?
Summary: Key Questions to ask during
importing

44. Agenda
44
Regulatory background and framework
Importation procedures
Additional approvals – special types of foods
2
3
1

45. Why new types of food?
• We know that Israel is a country with extreme
strong innovation ability
• Does innovation is encouraged in any area?
– Maybe No for food area
– Food safety should be taken cautiously
– How to prove safety?
• Toxicology tests
• Human test (eating history)

46. Why new types of food?
• Chinese government’s attitude towards new
types of food:
– Cautious cautious and cautious
– Will not let Chinese people be the testing rats
– Needs approval for new types of food

47. What are new types of food?
• New food raw materials
– No eating history IN CHINA
• New food additives
– Not listed in GB 2760 or listed but not the existing
categories or out of the limitation
• New food contact materials
– Not listed in GB9685

48. What need to provide for the approval
Common Emphasize points
New food raw materials Toxicology data; eating
history; exposure amount
Eating history
New food additives Toxicology data; using
history
Why added into food?
New food contact
materials
Toxicology data; approved
in other countries
Why added into the FCM?

49. Cost to get the approval
Cost (RMB)
• Depends on the
available data
• Depends on the
usage/migration level
• Depends on the
approval situations in
other developed
countries (US, EU, JP)
Lead time (year)
• Depends on the testing
items
• Depends on the
administrative speed
• Usually the
supplementary
data/information
should be provided for
a second time review
New food raw materials 50k* – 1000k >1
New food additives 50k – 200k 1-2
New food contact
materials
200k – 1000k 1-2

50. Procedures are similar
Testing
Prepare
dossiers
Submit to the
reception
office
Format
Checking
1st Technical
Assessment
Review
On-site
presentation
Supplement
information
2nd Technical
Assessment
Review
Get the
approval

51. Foods with special claims
• Health food
– Health food with health claims
– Nutritional supplements
• Special dietary food
– Infant formula, food with no sugar, sports
nutrition food, etc.
– Food for special medical purpose

52. What need to provide for the approval
Health food with
health claims
Nutritional
supplements
Special dietary
food (general)
Food for special
medical purposes
Registration –
getting “Blue hat”
Product filing No additional
obligations
Register with CFDA
Animal or/and
human tests
Hygienic stability
tests
Comply with
product standard
Clinical trial
Unpredictable of
the results
If filing system
could be easily
done,
straightforward,
low cost
Unpredictable of
the results

53. Thank you for your attention!
Email: laura.wang@cn.reach24h.com
www.reach24h.com
53