National food safety standard systems provide the backbone for supervision of wine products in China. In 1984 the former Department of Light Industry released QB 921-84 Wines and Their Test Methods, the implementation marked the beginning of standardized manufacture of wines in China. From 1994 to 2004, the industry standard “QB/T 1980-1994 Half Base Wine” left a regulatory loophole open allowing manufacture of blended wines with chemical components. The market chaos caused by this oversight didn’t end until 1st Jul 2004 when blended wines were officially banned. Following this China began more reform of wine-related standards and rules, including the drafting of new standards and provisions. In 2013 former NHFPC (now NHC) was created and replaced the former Ministry of Health. After institutional reform in 2018, National Health Commission (NHC) replaced NHFPC and is responsible for setting national food safety standards in accordance with provisions in Food Safety Law.
1. China's regulations and standards for wines
Most regulations overseeing the importation of alcoholic beverages generally apply to that of wines. In addition, there are also some specific regulations and standards made regarding the manufacture, procurement, sales and other aspects of wines.
Before QB/T 1980-1994 Half Base Wine expired on 1 Jul 2004, water-blended fruit wines were permitted for sale in China and could be labeled wine. After the standard was repealed China began a widespread reform campaign targeting relevant standards and regulations bringing about a well supervised regulatory system backed by sound legislation.
1.1 Major Wine Regulations Effective in China
|President Order 21 of 2015||Food Safety Law《食品安全法》||2015/10/01||The law at the top of all food-related regulations|
|GAC Order 249 of 2021||Measures for Administration of Imported/Exported Food Safety 《进出口食品安全管理办法》||2022/1/1|
|SAMR Order 24 of 2020||Measures for Administration of Food Production Licensing 《食品生产许可管理办法》||2020/3/1||The basis that requires all food producers in China to procure a production license|
|former AQSIQ Order 55 of 2012||Administrative Provisions on Filing of Importers and Exporters of Imported Foods 《进口食品进出口商备案管理规定》||2012/10/1|
|former AQSIQ Order 55 of 2012||Administrative Provisions on Recording of Import and Marketing of Imported Foods 《食品进口记录和销售记录管理规定》||2012/10/1||Management in the stage of domestic circulation, mainly on the consignee part|
|former AQSIQ Notice on Dec 23 2004||Rules for Inspection on Production Licensing of Wines and Fruit Wines 《葡萄酒及果酒生产许可证审查细则》||2005/1/1|
|former AQSIQ Order 78 of 2005||Geographical Indication Product Protection Regulation 《地理标志产品保护规定》||2005/7/15||Champaign(2013), Bordeaux(2014), Napa Valley NV(2013)|
Several provinces and cities have already had localized alcohol administrative regulations implemented, which have successfully stimulated the smooth development of regional alcohol industry. There is no lack of comparable precedents since overarching regulations for other special foods like dairy, genetically modified foods and salt have been formulated.
Since Geographical Indication Product Protection Regulation became effective in 2005, Champaign, Bordeaux, NAPA VALLEY NV and several other terms have gained geographical protection in China. This regulation is quite linked to similar regulations like EU’s Protected Designations of Origin (PDOs), and will help reduce the number of counterfeit products in the Chinese market.
1.2 Mandatory National Standards for Wines
|Product Standard||GB 2758-2012 Fermented Alcoholic Beverages and Their Integrated Alcoholic Beverages 发酵酒及其配制酒||2013/2/1||Outlining general standards for fermented alcoholic beverages and their integrated alcoholic beverages, including terms and definitions, technical requirements and labeling|
|Labeling Standard||GB 7718-2011 General Standard for The Labeling of Prepackaged foods 预包装食品标签通则||2012/4/20||Outlining general requirements of all kinds of pre-packaged foods including wines, the content involves ingredients, date of manufacture, date of maximum durability, specifications, etc.|
|General Standard||GB 2760-2014 Standard for Usage of Food Additives 食品添加剂使用标准||2015/5/24||Specifying using rules of food additives, allowed types of food additives, application scope, maximum levels of usage and residue|
|General Standard||GB 2761-2017 Maximum Levels of Mycotoxins in Foods 食品中真菌毒素限量||2017/9/17||This standard includes lists of maximum levels of mycotoxins in foods, among which is the maximum level of palutin in alcoholic products including wines|
|General Standard||GB 2762-2017 Maximum Levels of Pollutants in Foods 食品中污染物限量||2017/9/17||This standard specifies maximum amounts of lead in alcoholic products including wines|
|General Standard||GB 2763-2021 Maximum Levels of Pesticides in Foods 食品中农药最大残留限量||2021/9/3||Manufacturers of wines refer to this standard for the maximum levels of pesticides in grapes|
|Production Standard||GB 12696-2016 Hygienic Specifications of Factories for Wine 葡萄酒厂卫生规范||2017/12/13||This standard specifies requirements of wine factories, especially applicable to bulk imported wine process|
1.3 Recommended Standards for Wines
|Product Standard||GB/T 15037-2006 Wines 葡萄酒 |
|2008/1/1||Dictating the terms and definitions, product classification, requirements, analytical methods, inspection rules and labeling, package, transportation, storage of wines|
|Analytical Standard||GB/T 15038-2006 Analytical Methods of Wine and Fruit Wine 葡萄酒、果酒通用分析方法||2008/1/1||Outlining sensory, physical and chemical analytical methods of wine and fruit wine (the determination method of methanol is replaced by GB 5009.266-2016 National Food Safety Standard - Determination of methanol in food stuffs; the determination method of ethanol is replaced by GB 5009.225-2016 )|
|Production Standard||GB/T 23543-2009 Good Manufacturing Practice for Wine Enterprises 葡萄酒企业良好生产规范||2009/12/1||GMP for producing wines in China|
|Terms||Norm of Terminology Translation of Imported Wines 进口葡萄酒相关术语翻译规范||2015/09/01|
2. Competent authority
General Administration of Customs (GAC)'s main supervisory scope is the import and export inspection of wines.
National Health Commission (NHC) holds the obligation of drafting and releasing national standards related to wines.
*China has undergone department restructure in 2018. If you are confused about the competent authorities, please click here to read more.
3. Tips on wine export to China
There are several checkpoints that wine exporters, agents and importers should pay attention to when trading wines in China.
3.1 The filing of exporters or agents with GAC
According to Administrative Provisions on Filing of Importers and Exporters of Imported Foods (former AQSIQ Order 55 of 2012), overseas exporters or agents shall fulfill record filing obligations with GAC through the filing management system (http://ire.customs.gov.cn/) prior to exportation. The application form for filing should be submitted through the online platform with information such as authentic names of the exporter or agent, country/region, address, contact person, phone number provided.
After submitting the application form, exporters or agents will receive a file number and an inquiry number produced by the filing management system and with these numbers they can check their filing proceeding status and amend filing information.
3.2 The filing of importers or domestic agents with GAC
Consignees (importers or domestic agents) shall apply for filing at local industry and commerce department; the documents required may vary in different ports but in general are required as follows:
An accurately completed application form for consignee filing
A copy of industry and commerce business license, organization code certificate, identification paper of the legal representative, registration form for the filing and recording of foreign trade operators, with the original submitted for verification at the same time
Documents on the quality and safety management system of the enterprise
Documents on organization structure, department functions and job responsibilities concerning food safety
Documents on planned food category of operation and storage location
Explanations, including the food category and quantity, reporting on the last two years’ history of food importing, processing and marketing
Similar to exporter filing, consignees need also fill and submit the application form through the filing management system (http://ire.customs.gov.cn/) and obtain a filing number.
After products are imported, importers must keep the import and sales information on record for a minimum of 2 years for future reference. Detailed information includes filing documents of imported record, product supply chain, complaint/recall record, filing documents of sales record.
3.3 USA's wine export certificate (applicable to US wines only)
As was agreed with the US competent authorities, General Administration of Customs and former AQSIQ jointly announced that since 1 Mar 2014 a wine export certificate will be used as a multi-purpose certificate for wine products exported to China. Hence Certificate of Origin, Certificate of Health Sanitation or Certificate of Authenticity/Free Sale will no longer be issued from US authorities for the Chinese wine market. (Notice No. 164, 2013 of AQSIQ and GAC)
4. Requirements of labeling in Chinese
Imported wines in China require back labels in simplified Chinese corresponding to original labels and products attached prior to market circulation. There are two options: use label stickers placed on top of the original labels before the batch of wines is exported to China or conduct the process at port/bonded area. Either way requires compliance check after arrival.
According to GB 15037-2006 Grapes, GB 7718-2011 General Standard for The Labeling of Prepackaged foods, information required on the labels of imported wines include: name, type and vintage of product, ingredients, alcohol content, country of origin, net content, manufacturer, name, address and contact of distributor, storage conditions, filing date and shelf life, food additives, barcode, etc.
figure1: China wine compliance flow
Information such as country of origin, filing date shall be consistent with documents provided by the exporter or overseas agent. Filling dates require certificates of bottling dates provided by producers.
Food additives must be shown on the label. Sulfur dioxide is the most commonly used food additive in wines. If other food additives are used, the labeling of these food additives shall be in line with requirements in GB 2760-2014 Standard for Usage of Food Additives.
If specific information outlining awards and accolades are included certificates and other valid proof shall be submitted for check.
In accordance with GB 7718-2011, the health warning “过度饮酒有害健康”, which means excessive drinking will harm your health, shall be presented on the label.
On condition that the original label is not fully covered by the Chinese one, the foreign language content exposed shall be translated and presented on the Chinese label.
High tariffs have been imposed on imported wines in China which in turn will raise the retail prices. In general, the tariffs of bottled wines are as follow:
Import tariff: Tariff rate of wines for most favored nations: 10%.
VAT (value added tax): 13%. (CIF + tariff) x 13%)
Consumption tariff: 10% [(CIF + tariff)/ (1-10%)] x10%)
The sum total rate of tariffs for bottled wines should be 33%. VAT and consumption tariffs also apply to domestic wines.
It is notable that import tariffs can vary between countries. New Zealand has the advantage of Free Trade Agreements (FTA) meaning its import tariff rate for wine has been zero since 2012. Chile is also the beneficiary of FTA, and its import tariff rate is estimated to drop to zero in 2015.
5.1 Import tariff rate of bottled wines for major wine exporting countries in China
|Country||Tariff rate 2022 (%)||FTA|
6. Expert Article & Ebook
Daisy Suo, 12 Dec 2014, China Wine Trade 2014: A Sluggish Year for Imported Wines
Daisy Suo, 16 Sep 2014, Export Wine to China: Manganese Blocking Aussie Winemakers’ Entry
Timothy J Trent, 7 April, 2017, Wine: a trending taste for China
Chris Wang, 2 Feb, 2018, China's Wine Imports Increase in Volume and Value in 2017