On November 26, 2019, the General Administration of Customs (GACC) solicited public opinions on the Regulations on the Administrationof Registration of Overseas Manufacturers of Imported Foods (Draft). The deadline for opinions is December 25,2019. We

After thorough study and comparison with the current version of the regulation, We highlighted few key points appeared in the draft version of the regulation, for your reference.

Provisions relating to the Directory of the Implementation of the Registration of Overseas Manufacturers of Imported Food (hereinafter referred to as “Directory”) were not shown in the draft version, related content was replaced by “Overseas Manufacturers of Imported Food that export food to china shall obtain the registration approval from GACC”.

Currently, overseas manufacturers of dairy products (excluding infant formula), infant formula, meat products, aquatic products and edible bird’s nest need to apply for registration before they export food to China. In the future, overseas manufacturers of all imported foodmight be required to obtain the registration approval. Meanwhile, a registration management based by category might be implemented by GACC. 

The draft version stipulated in details, regarding the supervision and management responsibilities of the exporting country's competent authority before, during and after the registration of overseas manufacturers of imported food. Also, Article 21 stipulated the measures need to be taken when inadequate supervision of the competent authority of the country occurs.

3. Planned to determine emphasis, method and frequency of supervision and inspection for registered manufacturers based on different risk levels

For the first time, the draft version proposed the annual verification and reporting system, replacing the regular review system, as a supervision and management means. That is, for imported food with higher levels in food safety risks and in consumer sensitivity, GACC will implement annual verification and reporting systems to corresponding registered overseas manufacturers.

4. Possible changes of registration dossiers

Planned to request: The inspection report of the company issued by the competent authority of the country, a statement that the company promises that its sanitary conditions and production process can continue to meet Chinese requirements.

Planned to neglect: No more requirements for business registration applications and the relevant floor plans and production processes. www.foodfeed.cn

5. Validation of Registration certification planned to be extended to 5 years

Validation was replaced by 5 years in the draftversion, instead of 4 years in the current version.