It’s been 3 years since China AQSIQ implemented the Administrative Provisions on Registration of Overseas Manufacturers of Imported Foods (AQSIQ Order No.145-2012), which is the regulatory basis for CNCA registration.
Change: Catalog management to full registration
Confirmation of future registration requirements for all overseas manufacturers of imported foods was provided by Mr. Ye Zhiping from Shanghai CIQ at REACH24H Food Summit. Only foodstuffs made by these CNCA-approved manufacturers will be permitted to be sold in China, meaning a significant change in future regulatory and market access requirements.
Currently, the regulation adopts catalog management. So far meat, aquatic products, dairy as well as bird’s nest have been listed into the catalog (go to F-lists to find out those approved) of foreign foodstuffs whose manufacturers need to be registered with CNCA. Honey and canned foods would probably be the next food categories that are require CNCA certification. indicated by Mr. Ye.
During the Summit, Mr. Ye also revealed how Chinese officials carry out the registration work.
CNCA registration criteria
Exporting country approval: The veterinary services system, the plant protection system and the public health management system of the exporting country shall be evaluated by CNCA before successful registration.
Plant and animal derived raw materials should not contain any pathogenic organisms or be associated with any regional zoonotic epidemics or originate from regions associated with these problems.
Manufacturer approval: The manufacturer must be a legal entity and fall under the supervision of regulatory authorities in the country of origin. Its production, hygiene and quality control systems, etc. must be compliant with Chinese regulations and standards.
Registration steps
Overseas manufacturers cannot apply to CNCA directly but should be recommended by the competent authority in its country. In other words the foreign competent authority acts as a guarantor for manufacturers it approves. Overseas manufacturers prepare required materials as outlined in AQSIQ Order No.145-2012 in addition to other documents issued by CNCA (may vary according to the product type).
CNCA organizes experts to review documents, conduct on-site inspection and form an examination report.
The validity for registration is 4 years.
The CNCA will not conduct onsite inspection of every manufacturer but will conduct random inspections (e.g. aquatic product manufacturer). However, CNCA officials must conduct onsite inspections of manufacturers of high risk product lines (e.g. infant formula manufacturer).
Follow-up management after registration
Re-examination if necessary
Apply for alteration of company name, product site, registered product types, hygiene quality system
Re-registration if there is major change
Revocation of registered status if any severe problems occur
We provide full-scale global food market entry services (including product registration, ingredient review, regulatory consultation, customized training, market research, branding strategy). Please contact us to discuss how we can help you by 
