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On the 14th of July CFDA issued a statement clarifying that all infant formula and FSMP product imported prior to Jan 1st 2018 can be sold until its expiration in China. To clarify the situation CFDA has also stipulated that all product must have undergone full compliance inspection and approval before the January 1st deadline to be eligible for this infant formula and FSMP registration transitional measure.
The legal basis for this clarification is laid down in “General Administration on the Transitional Period for Registration of Food for Special Medical Use (No. 119 of 2016) and the Announcement on the Transition of Registration and Administration of Infant Formula Milk Products (No. 160 of 2016)”.
The announcement has significant impact on manufacturers/exporters of unregistered IF and FSMP products exported to China as they must now carefully consider final shipment schedules to ensure that products have enough time to reach Chinese ports and get relevant approvals before the deadline. It is expected that many exporters will attempt large shipments towards the end of the year to take advantage of these transitional measures and buffer the impact of the registration rule. This increase in consignments and product volume is likely to stretch CFDA and AQSIQ inspection capacities. Delays are entirely possible and exporters are advised to err on the side of caution with respect to their logistics and customs clearance estimates.
*ChemLinked also wrote an article about the influence of this stipulation on the China infant formula market in our Market Insights column.
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