During the 2015 REACH24H CRAC Food Summit, Mr. Chen Jianliang from Shanghai CIQ delivered a speech regarding the food import process under the new food safety law.
Separation of supervisory functions
The new Food Safety Law has clearly defined the respective functions of AQSIQ and CFDA for imported food, which are generalized as:
AQSIQ (CIQs) shall be responsible for the entry permission of imported food.
CFDA (FDAs) shall take charge once imported foods enter into China.
Responsibility of manufacturers, exporters and importers
Under the 2009 FSL foods are subject to analytical testing conducted by accredited labs. Under the new FSL lab evaluation will no longer be the sole assessment criteria. Imported foodstuffs will be required to be accompanied by a quality certificate prepared by relevant enterprise.
Imported foods shall comply with Chinese GB Standards
It was highlighted during the speech that all the imported food, food additives and food related products shall comply with national food safety standards (refer to article 92 of the new Food Safety Law), totaling 492 at this stage. This implies that Chinese industrial standards and company standards will no longer be referenced.
New regulatory requirements for imported food without a national food safety standard
Upon the implementation of the new FSL, imported food without a referable Chinese national food safety standard can adopt the standards of the country/region of origin or any international standards. Supporting documentation needs to be submitted to the NHFPC. Provisional application should be granted by NHFPC once the standards pass relevant review. New GBs should be formulated after NHFPC approval.
Strict labeling obligations
The newly added article 94 has underlined the responsibility of overseas exporters and manufacturers to use compliant labeling. According to Mr. Chen, “Compliant Labeling of imported foods begins with overseas exporters and manufacturers”. Domestic importers shall undertake review of the labeling contents prepared by their overseas counterparts. Mr. Chen revealed that a new AQSIQ order is under discussion relating to labeling of prepackaged foodstuffs. Compared to the current requirements the labels shall be checked batch by batch and assessed under strengthened label inspection requirements.
Upgraded filing management system for importers & exporters
The upgraded system (see ChemLinked News) will be activated on 1 Dec 2015. Sales records of each enterprise should be inputted into the system for governmental random check and traceability.
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