New Details on China’s Overseas Food Facility Registration

In the spring of 2021, China published the Chinese General Administration of Customs (GAC) Decree 248 – Regulations on Registration and Administration of Overseas Manufacturers of Imported Food, to impose new registration requirements on all foreign food companies.

In October 2021, some foreign governments (e.g., Singapore and Malaysia) provided instructions to their local food companies on how to satisfy the overseas food facility registration requirements in China.  On October 5, 2021, the Singapore Food Agency (SFA) published a notice, which states that if the producers of certain designated food categories (e.g., edible fats and oils, functional foods, egg products, condiments) have exported the products to China since January 1, 2017, they could be entitled to GAC’s fast-track registration if they can submit their declaration to SFA by October 31, 2021.  The Malaysian food authority also posted detailed guidance to facilitate the registration in China.

Although the enforcement date of January 1, 2022 is approaching, no official guidelines have yet been released by GAC to detail the implementation.  An overseas food company may want to reach out to the local responsible food authority to understand whether any conversation has taken place between China and its home country as to how to comply with the Chinese food facility registration requirement.

Note also that GAC Decree 249 – Administrative Measures on Import and Export Food Safety, under which new requirements governing the inspection and evaluation of imported foods are imposed, will also take effect on January 1, 2022.