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The registration of overseas manufacturers of dairy products is a new mandatory obligation stated in the AQSIQ Order No.152-2013. Overseas companies are further required to finish the registration according to AQSIQ Order No. 145-2012 before 1 May 2014. Otherwise, dairy products made by those unregistered premises will be prohibited from exporting products to China. A raft of foreign producers of baby formula from Australia, New Zealand, EU, etc. are anxious over how to comply with the new policy due to the absence of detailed registration documents.
Recently, China CNCA, the department responsible for registration of overseas manufacturers of dairy products, published several related documents, including the registration application form (AF), questionnaire on dairy management in exporting countries, questionnaire on good manufacturing practice regulations/standards in exporting countries, etc. It is worth mentioning that the producer must be recommended by the competent authority of the country to the CNCA when applying for registration.
The contents of the AF include the following two main parts, indicating the authority’s intention to collect rather comprehensive info about the manufacturers, brands and even their supply chain relationships.
Table: Two Main Parts of the Registration Application Form
| Part I General Info about the Enterprise | Part A. General info (production enterprise, contact person, name of products to be exported to China, registered trademark) |
| Part B. Production information (production process, production capacity and equipment, hygiene and quality management system) | |
| Part C. Raw material information | |
| Part D. Product traceability and recall | |
| Part E. Product testing | |
| Part F. Enterprise location and plant environment | |
| Part G. Enterprise Statement | |
| Part H. Confirmation by competent authority | |
| Part II. Overview of Enterprise’s Export to China | Part A. Import information (e.g importer info, list of trademarks) |
| Part B. Export information |
It is highlighted by the CNCA that only those brands listed by manufacturers in the AF will be permitted to be imported to China. Brand owners and exporters that do not manufacture infant formula do not need to fill in the form. However, New Zealand MPI strongly recommends them to work closely with their manufacturers to ensure their brand information is included and accurate in the AF. If all the materials are well filled out, the MPI will recommend the manufacturers and deliver the AF to China CNCA,
Dairy manufacturers in other countries also need to actively communicate with the corresponding competent authorities for solutions and support. The tough registration will reshuffle the imported dairy brands and insiders predict that small manufacturing firms abroad will face extreme challenge to access to Chinese dairy market.
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