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In China, pet supplements are regulated as one type of pet foods under the animal feed legal framework. Stakeholders aiming to enter the Chinese pet supplement market must adhere to both general animal feed regulations and specialized pet food regulations. It is important to note that pet food in China specifically refers to the feed for dogs and cats. (Read more at ChemLinked Food-pedia: China Animal Food Regulation)
In this article, ChemLinked outlines the key compliance steps and regulatory requirements for selling pet supplements in China. For details about each compliance step, please refer to ChemLinked's webinar:
Step 1: Product classification
Before entering the Chinese market, businesses must accurately classify their products, as this will determine applicable regulations and compliance requirements. For instance, pet milk may be classified as complete pet food, nutritional supplement, or pet snack, depending on its formulation and intended use.
According to the Administrative Measures for Pet Foods, pet food in China is categorized into three types:
Pet compound feed: feeds prepared by mixing a variety of feed raw materials with feed additives according to certain proportions in order to meet the nutritional requirements of pets at different life stages or under specific physiological and pathological conditions, which can be used alone to meet the full nutritional requirements of pets.
Pet additive premix feed: feeds prepared by mixing nutritive feed additives with carriers or diluents according to certain proportions in order to meet pets’ requirements on nutritive feed additives such as amino acids, vitamins, mineral trace elements, and enzyme preparations, etc.
Other pet feed: feeds prepared by mixing several feed raw materials with feed additives according to certain proportions for the purpose of rewarding pets, interacting with pets, or stimulating chewing or biting by pets, etc.
Products intended as nutritional supplements generally fall under the "pet additive premix feed" category.
Step 2: GACC approval: national-level market access permit
Before investing in the Chinese market, businesses must ensure their exporting country has a national-level market access permit from China’s General Administration of Customs (GACC). Only permitted manufacturers from permitted countries can export approved pet food products to China. To verify this, enterprises should consult the lists as listed below and ensure they are not listed in the negative list. For countries lacking a market permit, businesses should contact the competent authorities in the exporting country, who will then contact GACC for the national-level market access approval.
White lists for permitted products from permitted manufacturers and countries:
Negative list |
Step 3: Product compliance
As explained in the beginning of this article, enterprises must ensure the product compliant with both the general laws and regulations for all animal feed and the specialized regulations for pet food.
To be specific, Regulations on the Administration of Feeds and Feed Additives and the Administrative Measures for Imported Feed and Feed Additives Registration are the two overarching regulations. They have set fundamental principles for animal feed production, including the production of pet food. For example, it is quite important to know that “Feed or feed additives that are not approved for production, use, or are prohibited from production and use in the place of origin shall not be registered (in China).”
During the actual production of pet supplement, enterprises are required to following the key regulations as provided in the table below, regarding the use of ingredient, the sanitation requirements and the labeling requirements.
No. | Aspect | Corresponding regulations | Notes |
1 | Use of ingredient |
|
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2 | Sanitation | It sets the maximum limit of different types of pollutants, including inorganic pollutants and chlorinated compounds, mycotoxins, natural phytotoxin, organic chloride pollutants and microbiological pollutants. | |
4 | Labeling |
| Provisions on the Labeling of Pet Foods in China is the most practical regulation for pet food enterprises to follow in the aspect of product labeling, which sets the mandatory labeling items for product. |
Step 4: MARA import registration certificate
As according to the two overarching regulations for feeds, namely, the Regulation on the Administration of Feeds and Feed Additives and the Administrative Measures for Imported Feed and Feed Additives Registration, all imported pet food, excluding Other pet feed (e.g., pet snack), must obtain an import registration certificate with China’s Ministry of Agriculture and Rural Affair (MARA) prior to export.
Applications shall be submitted to this MARA online approval system. Once approved, the registration is valid for 5 years. Notably, feed or feed additives that are not approved for production, use, or are prohibited from production and use in the place of origin will be failed to get the MARA import registration certificate.
For most regular products, they need to prepare the following materials for the MARA import registration certificate:
Application form (in both Chinese and English)
Authorization letter
Proof of production and use approved at the origin country (legal basis, production certificate, free sales certificate)
Physicochemical properties
Product origin and composition
Manufacturing process (process flow chart and explanation)
Quality standard, testing methods
Labels used in origin country, label template in Chinese and trademarks
Usage purpose, scope and usage method
Packaging materials, size, shelf life and storage conditions (if it is a fermented product, then the storage situation of used bacterial shall also be explained)
Registration and application status in other countries and regions other than the origin country
Products using GMO ingredients shall get relevant approval. If the product may have the risk of dioxin, then provide a test report on dioxin.
Six samples (2 samples for each 3 batches)
Additional documents will be required for the application of new feed and feed additives.
Step 5: GACC approval: manufacturer registration
In practice, enterprises are advised to register their overseas manufacturers with GACC after completing Step 4.
In this step, enterprises need to first contact the competent authority in the exporting country and then the exporting country will contact GACC for the registration of manufacturers. Once the manufacturer registration is completed, the approved manufacturers can find their names in corresponding white lists provided in Step 2.
Step 6: Inspection and quarantine at ports
Measures for Inspection, Quarantine, Supervision and Administration of Imported and Exported Feed and Feed Additives is the regulation supervising the inspection and quarantine of imported feeds, including pet supplements. If the exporting country has reached a protocol, or similar documents, with China, then relevant requirements shall be met as well.
In practice, enterprises need to apply for an inspection and quarantine certificate for their pet foods, including pet supplements. At ports, local customs officials will conduct a sensory inspection and check the certificate against the goods and product label. A sampling examination will also be conducted.
Step 7: Domestic importer filing
Besides the registration of overseas manufacturers, the importer in China shall file with local customs officials before/during the first declaration for inspection as per Measures for Inspection, Quarantine, Supervision and Administration of Imported and Exported Feed and Feed Additives.
Step 8: Post-market supervision
After products are circulating in China’s market, they will be subject to the regular and/or irregular inspection conducted by the authority.
ChemLinked Solution: Feed and Pet Food Related Service
ChemLinked has been equipped with a professional technician team to provide a one-stop service with expertise and efficiency. Our services include:
Translation service
Consulting service
Registration service
- Review product composition
- Provide application material checklist and detailed requirements
- Check provided materials and feedback if any deficiency or inconsistency
- Compile application form and dossiers
- Submit application and track the progress
- Contact official laboratory for sample tests
ChemLinked has well served hundreds of global food enterprises in terms of market access. Please feel free to contact us via [email protected] if you need any help.
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