Obligation Checklist for Exporting Adult Milk Powder to China

Key points:

• General importation procedure and material needed when exporting products to China.

• Related regulations about exporting adult milk powder into China

Adult milk powder is categorized as a kind of formulated milk power in China. At present, there is no special law or regulation for adult milk powder. Therefore, the formula design, manufacture, packaging and circulation of adult milk powder should be conducted according to related requirements for formulated milk powder, and corresponding products should be imported in line with requirements for general imported dairy products. This article mainly introduces the import procedures of adult milk power into China and the required dossiers as well as relevant laws and regulations.

1. Import Process & Dossiers of Adult Milk Powder 

1.1 Qualification of the Importer 

• Food circulation permit (Dairy circulation);

• Food business license (Dairy circulation);

1.2 Import and export qualification (China Electronic Port Enterprise IC card, Membership of China Chamber of Commerce for Import & Export of Foodstuff and Native Produce, Manufacturer Filing of the Import Report of the Staple Agricultural Products, Automatic Import License, etc.)

1.3 The filing of overseas exporters

• Overseas exporters should fulfill record filing obligations with AQSIQ, and should be responsible for the authenticity of the submitted materials.

• The application form should be submitted through the filing management system (http://ire.eciq.cn), and information such as authentic names of the exporter, country/region, address, contact person, phone number should be provided.

• The list of filed exporters will be published on AQSIQ website.

1.4 The filing of domestic consignees

• Domestic consignees should apply for filing to the CIQs in local industry and commerce registration centers.

• The application form should be submitted through the filing management system (http://ire.eciq.cn), and information such as authentic names of the consignee, country/region, address, contact person, phone number should be provided.

• The list of filed consignees will be published on AQSIQ website.

1.5 The filing of labels

• A copy of original label and translation (which can be skipped provided that the label in Chinese rather than in other languages has been attached at arrival to the port). On condition that ingredients and food additives have not been comprehensively listed on the original label, a complete ingredient list of both English and Chinese shall be submitted separately

• Paper copy of Chinese label and attachment of specific information (which should include the name of manufacturer, Chinese name of the brand, physical contrast, etc.)

• Electronic copy of Chinese label, in case where the Chinese label is pasted over the original label, the spot where the Chinese label is placed should be specified

• Copies of the business licenses of the importer and distributor or domestic agent

• In case that certain contents such as award-winning, certificate-wining, AOC and geographical indication are highlighted in the label, corresponding certificate and translation shall be provided. Qualification certificates should be provided where nutritional contents are present.

• For first time imported products, once a product passed quality inspections, a label filing number should be attainable from the label management system. The importer should receive a label filing certificate from local authority by its product inspection number.

• Other certificates or supporting materials which are required.

2. Laws and Regulations Supervising Imported Adult Milk Powder

2.1 Relevant notices

• Administrative Provisions on Inspections and Supervisions of Labeling of Imported/Exported Pre-packaged Foods

• Administrative Measures on Inspection, Quarantine and Supervision of Import and Export Dairy Products

• AQSIQ Announcement on Relevant Requirements for the Implementation of the Administrative Measures on Inspection, Quarantine and Supervision of Import and Export Dairy Products

2.2 Relevant standards

GB 19644-2010 National Food Safety Standard Milk Powder

• Formulated milk powder means powder products that are produced from raw bovine milk or ovine milk or its processed products as the major ingredients, with addition of other ingredients, with or without addition of food additives and nutrition enhancers. The content of milk solids should not be less than 70% in final products. Milk solids in the powder include full-cream milk powder, skimmed milk powder, whey protein, demineralized whey powder, lactose, etc.

• According to GB 19644-2010, the content of protein in formulated milk powder should be no less than 16.5% while moisture content should be no more than 5.0%.

GB 14880-2012 National Food Safety Standard Standard for the Use of Nutritional Fortification Substances in Foods

• GB14880 stipulates the application scope and dosage of nutritional fortification substances in formulated milk powder (refer to Appendix A), and the corresponding allowable compound sources should refer to Appendix B. Take vitamin A, a kind of nutritional fortification substances, for instance, Appendix A provides the legislative ground that vitamin A is allowed to be added in adult milk powder with a dosage allowed in formulated milk powder (except for the milk powder used for children, pregnant women and lying-in women) being within the range of 3000µg/kg~9000µg/kg. Next, Appendix B could be referred to for the compound sources of vitamin A which should include acetate,retinyl ester (acid vitamin A), retinyl palmitate ester (palmitic acid, vitamin A), all-trans retinol and β-carotene. In actual production one or more compounds could be adopted.

GB 28050-2011 National Food Safety Standard General Rules for Nutrition Labeling of Prepackaged Foods

• Nutrition information and nutrition claims of adult milk powder should comply with this Standard.

• This Standard stipulates regulated nutritional components, their order, labeled unit, rounding interval and limit value of “0” as well as the nutrient reference value (NRV), nutrient content claims and nutrient comparative claims. Take dietary fiber for instance, total content of dietary fiber should be no less than 3g/10g in solid form and no less than 1.5g/100mL/1.5g/420kJ in liquid form. Standard nutrient function claim of energy and nutritional components should not be deleted, added, combined or arbitrarily compiled.

• Allowed error range for energy value and content of nutritional component:

• Expressing method of nutritional component: The content level of energy and nutritional components should be expressed in“amount per 100g” and (or) “amount per 100mL” and (or) “amount per serving”. Corresponding NRVs for the components should be present as well.

GB 7718-2011 National Food Safety Standard General Standard for the Labeling of Prepackaged Foods

This Standard stipulates labeling requirements other than nutritional labeling.

• Foreign characters may be used simultaneously in corresponding to Chinese for imported food, and all the foreign characters should not be larger than the corresponding Chinese characters. The height of words, marks, and numbers of mandatory labeling content shall not be less than 1.8m.

• For imported pre-packaged foods, name of the country of origin or name of the region of origin (Hong Kong, Macau, Taiwan, etc.) shall be presented, as well as the name, address and contact of legally registered agent, importer or distributor in China. The name, address and contact of the manufacturer may not be labeled (depending on the specific requirements of each port).

• Imported prepackaged food could be exempted from the labeling of relevant product standard code and quality grade. Authenticity and accuracy should be guaranteed where the code and grade are marked.

• All the ingredients in the original ingredient list should be included in the Chinese ingredient list. For an ingredient omitted from the original list, it should be added to the Chinese ingredient list if required by Chinese laws and regulations.

• There shall not be additional labeling, reprinting or tampering with labeled dates.

GB 2760-2014 National Food Safety Standard Standard for Uses of Food Additives

This Standard stipulates food additives allowed in food.

• According to Appendix E Food classification system, the classification number of milk powder is 01.03, and that of formulated milk powder is 01.03.02. All the food additives allowed to be added in products categorized in 01.03 and 01.03.02 could be added to adult milk powder, and the usage should conform to rules in GB 2760-2014.

• Food additives used should be labeled as the generic names given in GB 2760.It could be either labeled with a specific name, or labeled with the name of functional class with the specific name or INS number. However, the labeling method should be kept consistent on the same label.

GB 2761-2011 Maximum Levels of Mycotoxins in Foods

GB 2762-2012 Maximum Levels of Contaminants in Foods

3. Testing items of adult milk powder imported for the first time