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Change 1: Health Food Filing
Old law: Health Foods imported for the first time should be registered with CFDA
New Law: Once all the ingredients are already regulated under Chinese national Standards products will not require registration. In addition in the past it was necessary to provide documentation proving that the product had a history of at least one year safe market circulation in the country of origin. Under the new law it will be sufficient to provide documentation proving that the sale of the product is sanctioned by the competent food authority in the country of origin
Industry Impact: Market access requirements for non-novel health foods will be greatly reduced. Using Chinese national standards such as GB14880 as a reference it will be possible to develop new supplements that will be facilitated with greatly expedited market access. It is also highly likely the government will publish a positive list of health food ingredients.
Change 2: Total Supply Chain Management
Old law: The only major regulatory barrier for imported foods was CIQ inspection at port.
New law: There will be regulatory supervision throughout all stages of the supply chain. It is also likely that traceability systems currently being piloted for domestically produced foods will be expanded to included imported foods
Industry impact: Post market supervision and enforcement is highly likely to increase and in line with this the regulatory obligations for imported foodstuffs will increase accordingly.
Change 3: New Food Material Safety Assessment Dossier Filing
Old Law: All imported foodstuffs must conform to Chinese national standards. Foods that are not regulated under Chinese national standards and have no history of consumption in China require new food material registration. Under the old law only domestic agents could submit this material
New Law: Foreign importers and manufacturers will now be able to file safety assessment dossiers with NHFPC for approval.
Impact for Industry: Facilitates market access, especially for new food material health foods.
Change 4: Domestic Infant Formula Manufacturer Credit Rating System
Old law: No Precedent
New law: A corporate credit record system is to be implemented over domestic infant formula manufacturers whereby the CFDA will record quality and safety history assessed under specific criteria and accordingly assign a manufacturer rating which will be the basis for future regulatory supervision. The recording system will include information such as, basic corporate information, production license information,regular inspection information, sampling inspection information, risk monitoring information, Illegal activity information, product recall information, food safety accident information,regulators reported information Consumer complaints information Social Supervision Information media coverage information.
Impact for Industry: China's Domestic Infant formula industry will be given a major tool to help boost consumer confidence and faith in the quality of domestically produced infant formula.
Change 5: Food Recall System
Old Law: No comprehensive precedent
New Law: A comprehensive recall system controlling all relevant parts of the food supply chain. Will be broadly divided into a general recall system and an emergency rapid response recall system. The system will offer a platform to record relevant information and clearly outline the requirements for recall, halting or ceasing production of foods, traceability etc.
Impact for Industry: The new recall system will govern all aspects of China's food industry.
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