Importation Requirements for Aquatic Product in China

In recent years imported aquatic products are becoming more and more popular in China. Take salmon for example, in 2010 the national importation volume reached 12 thousand tons and in 2014 it was more than 30 thousand tons with an annual increase of 25%. This article details requirements for aquatic products both in traditional trade and through cross border e-commerce.

Traditional importation trade

Access approval

In order to prevent diseases carried by aquatic products from spreading, and guarantee public safety, Chinese government has set strict access requirements on imported aquatic product, including its species, country of origin and manufacturing enterprises. All those three aspects mentioned above must be approved by AQSIQ prior to exporting products to China.

• Approved countries and species

In 2012, Food Safety Authority under AQSIQ released an announcement related to inspection work of imported aquatic products, stipulating that only countries (regions) and species accredited by China are permitted to be imported in China. By 2015, more than 7000 species from more than 100 countries (regions) had obtained importation approval to China. Please click here to see the detailed information.  

• Registered Manufacturing Enterprises

In 2012, AQSIQ issued the Directory for Registered Overseas Manufacturing Enterprises of Food Importation, including aquatic product to the list for the first time. It means that only aquatic products from enterprise (processors) listed in the directory are permitted to be imported. Any foreign enterprise must apply for filling first before entering the Chinese market. If the inspection and quarantine department finds unqualified products, safety risks, or some negative records, the corresponding enterprise may be removed from the directory of approved enterprise. For example, in Shanghai, if the imported products from different overseas enterprise is found unqualified 3 times, or if 1 enterprise is found unqualified twice in 1 year, the importer or overseas manufacturing enterprises will have their filing qualification rescinded and must apply for filing again after the problems and risks have been resolved. Please click here to see the latest directory for overseas aquatic products manufacturing enterprises.

Inspection and quarantine

After meeting the requirements of access approval, aquatic products are permitted to be exported to China, however it does not mean that they could enter into Chinese market successfully. Firstly,  Administrative Measures on Inspection and Quarantine of Imported and Exported Product stipulates that imported aquatic products must be attached with AQSIQ approved Inspection and Quarantine Certificates issued by country of origin. AQSIQ’s approval means that the imported aquatic products have already met the inspection requirements regulated in the agreement signed with the country/region of origin. In August, 2016, there were 84 countries approved, mainly in Asia (22) and Europe (27). Those approved countries and species are listed into a directory, which are updated on the website of Food Safety Authority under AQSIQ

Besides, China sets extra requirements on high risk aquatic products. In article 13 of Administrative Measures on Inspection and Quarantine of Imported and Exported Product, it stipulates that AQSIQ applies an inspection and quarantine system to high risk aquatic products, including amphibian, reptiles, aquatic mammals, salmon and other aquaculture products, and aquatic products originating in Japan. All those aquatic products have been listed into the Directory of Aquatic Products Species Requiring Inspection and Approval. It means that those products mentioned above require License for Quarantine of Entry Animals and Plants prior to customs inspection. The consignee, usually the importer, needs to apply for License for Quarantine of Entry Animals and Plants before the contract or agreement signing. However, the requirements of License for Quarantine of Entry Animals and Plants are just subject to aquaculture products rather than wild captured aquatic products.

In addition, according to announcement of Regulation on Filing of Food Importers and Exporters and Regulation on Food’s Importation and Sales Record, besides food exporter, agent and Importer require filling as well.

Tax payment is also an important section during importation. The following chart illustrates rates of imported aquatic products:

The most favored nation rate applies for countries that have signed trade agreement with China; otherwise, a much higher general rate applies while calculating customs duty. And VAT is based on customs duty, VAT rate and CIF value.

The last step of market entry is customs inspection. Here CIQ will check the documents related to the products, including:

1. Inspection and Quarantine Certificates issued by origin countries (regions), exported countries (regions), or flag countries.

2. certificate of origin

3. inventory of imported animal source products

4. imported food safety commitment

5. Trade documents such as bill of lading, invoice, contract, packing list.

6. For products listed into Directory of Aquatic Products Species Requiring Inspection and Approval , Preliminary verification sheet of License for Quarantine of Entry Animals and Plants or Declaration of Imported Cultured/ Wild Aquatic Products (except that cultured/wild has been indicated in official foreign inspection document) is required

7. Translation of original label

Apart from documents review, CIQ will conduct sample inspection on the quality of products. The Chinese government has also set a series of regulation and standards related to sensory requirements, physical and chemical index, maximum residue limit of veterinary drug, etc. Here are several important standards and announcement related to aquatic products:

• GB 2733-2015 National Food Safety Standard Fresh and Frozen Aquatic Products of Animal Origin

• GB 10136-2015 National Food Safety Standard aquatic products of animal origin

• GB 2762-2017 National Food Safety Standard Maximum Levels of Contaminants in Foods

• GB 2763-2016 National Food Safety Standard Maximum Residue Limits for Pesticides in Food

• Maximum residue limit of veterinary drugs in animal source food (NO.235 announcement released by Ministry of Agriculture in 2002)

After both documents and quality are qualified, Inspection and Quarantine Certificate of Entry Goods is issued, indicating the aquatic products have been approved and have entered the Chinese market successfully.

Cross border e-commerce (CBEC)

As one of the hottest pathways of international trade in China currently, cross border e-commerce has attracted the world’s attention. On April 6, 2016, 11 departments including Ministry of Finance, AQSIQ issued the positive list of imported products through CBEC. On April 15, the second batch of the positive list was issued, containing aquatic products.

*list of aquatic products in the second batch of the positive list for CBEC

From the list above it can be seen that only 11 kinds of aquatic products are permitted to be imported through CBEC by bonded warehouse model. Compared to common products like chocolates, aquatic products are set stricter requirements as they are regarded as high risk foods. Since it is imported by bonded warehouse model, it still requires relevant documents, inspection and quarantine etc, almost as much as normal trade. At present due to strict control by government, it is hard to develop an aquatic products business through CBEC. On April 20, 2017, a batch of “Dungeness” crab from San Francisco arrived at Hangzhou Xiaoshan International Airport CIQ. It was the first time for Hangzhou airport CIQ as well as Hangzhou cross-border e-commerce park to have aquatic products imported through CBEC. Maybe in the future, with the development of CBEC and the improvement of related regulations, CBEC will become a popular pathway for aquatic products.