Take home:
China CFDA will require the registration of infant formula formulations. The relevant rule is under formulation.
Unregistered IF products are allowed to be traded through cross-border e-commerce channel before 1 Jan 2018.
China’s CBEC Positive List which was issued on 7 Apr 2016 contains infant formula products with the precondition that they should be registered with CFDA first (see CL Food News on 8 Apr 2016). The restriction has caused tremendous confusion among infant formula companies as CFDA has not even finalized the “Administrative Measures for Registration of Infant Formula Formulations” yet, which is still in its opinion-soliciting period among WTO members (see CL Food News on 15 Jan 2016).
The good news is on 13 Apr China Ministry of Finance after listening CFDA’s opinions on this issue announced to allow continuous import of unregistered infant formula by cross-border e-commerce platforms since the registration rule has not been completed.
From 1 Jan 2018, all imported IF products including those traded through CBEC should be registered with CFDA prior to import. The deadline also indicates the pending registration rule is probably to be issued this year in order to leave a transition period for IF manufacturers to finish product registration before implementation.