1. Competent authority
| Competent authority | Responsibility |
| State Administration for Market Regulation (SAMR) | Market supervision Administration on special food, including infant formula registration |
| National Health Commission (NHC) | National standard drafting New food ingredient registration |
| General Administration of Customs of China (GACC) | Customs inspection, quarantine, and declaration Overseas food manufacturers registration |
2. Market access approval
2.1 Import permit at state level
Only dairy products that passed the national assessment can be exported to China. Please refer to Catalogues of Foods Exported to China from Countries or Regions That Meet the Assessment and Examination Requirements and Conduct Traditional Trade with China for the permitted dairy species and their exporting countries/regions.
2.2 Overseas manufacturer registration
According to the Administrative Provisions on Registration of Overseas Manufacturers of Imported Foods, overseas manufacturer registration is mandatory for all imported food products and the registration of dairy manufacturers should be recommended by the local competent authorities.
Recommended resources:
Webinar: Prepare for China’s Overseas Food Manufacturers Registration Under New GACC Requirements
Webinar: A Tutorial Guide & FAQ for GACC Overseas Food Manufacturer Registration
2.3 Inspection and quarantine
The following four types of dairy products are subject to inspection and quarantine while exporting to China:
| Dairy products | HS code |
| Raw milk | 0401200000 |
| Raw milk products | 0403100000, 0406100000, 0406200000, 0406300000, 0406400000, 0406900000 |
| Pasteurized milk | 0401100000, 0401200000 |
| Modified milk produced by Pasteurization | / |
Recommended resources:
2.4 Exporter and importer filing
Regardless of food categories, the overseas exporters or agents and importers in China shall log into this system and get themselves filed with GACC.
To have a better understanding of China’s food import procedure and supervision mechanism, please check ChemLinked online course: Regulatory Compliance and Import Procedure of Prepackaged Food in China
3. Product compliance
3.1 Product requirements
The national food safety standards specify the definition and technical requirements (ingredients, sensory requirements, physicochemical indicators, microorganism level, etc.) of dairy products. Please refer to the corresponding GB standards for more details:
| Dairy products | Referenced GB standard |
| Raw milk | GB 19301-2010 Raw Milk |
| Pasteurized milk | GB 19645-2010 Pasteurized Milk |
| Sterilized milk | GB 25190-2010 Sterilized Milk |
| Modified milk | GB 25191-2010 Modified Milk |
| Fermented milk | GB 19302-2010 Fermented Milk |
| Condensed milk | GB 13102-2010 Evaporated Milk, Sweetened Condensed Milk and Formulated Condensed Milk |
| Condensed milk | GB 19644-2010 Milk Powder |
| Milk powder | GB 11674-2010 Whey Powder and Whey Protein Powder |
| Whey powder | GB 19646-2010 Cream, Butter and Anhydrous Milkfat |
| Cream, butter and anhydrous milkfat | GB 19646-2010 Cream, Butter and Anhydrous Milkfat |
| Cheese | GB 5420-2021 Cheese |
| Processed cheese | GB 25192-2010 Process(ed) Cheese |
Recommended resources:
Online course: China Dairy Industry: Regulation Dynamics and Business Opportunities
3.2 Label
The labeling of dairy products should follow the general rules such as GB 7718-2011 General Standard for the Labeling of Prepackaged Foods, GB 28050-2011 General Rules for Nutrition Labeling of Prepackaged Foods and other relevant regulations. Moreover, the additional requirement for imported dairy products is the mandatory labeling of registration No. of overseas manufacturers.
It is noteworthy that dairy products are subject to some additional labeling requirements specified in their GB standards. Take pasteurized milk for example, one of the additionally labeling items is that Chinese characters of “fresh milk (cow) milk” (鲜牛(羊)奶) shall be indicated close to the product name on the principle display panel. You can check the GB standards listed in 3.1 for more labeling requirements.
ChemLinked has well served hundreds of global food enterprises in terms of market access. Please feel free to contact us if you need any consultation service.
