China Issues Temporary Permits for Exhibition of Unregistered Imported Infant Formula and Health Food at Expos

SAMR will now issue temporary permits for unregistered special foods in a move to facilitate overseas special food stakeholders who do not have a formula registration certificate but are eager to participate in China International Import Expo (CIIE)

In a startling policy u-turn, on Aug. 17, 2018, State Administration for Market Regulation (SAMR) published a notification permitting the issuance of temporary permits for unregistred special foods, just two months after China's General Administration of Customs (GAC) detailed the exhibition prohibition list and restriction list for CIIE exhibition, which stipulated that registration or filing of infant formula and health food and registration of overseas dairy manufacturers was required for all exhibitors.

Manufacturers of infant formulae or health food who have not obtained registration approval may apply for a temporary access permit with Shanghai Food and Drug Administration if they have obtained a hygiene certificate issued by the relevent food safety authority in the country of origin. Shanghai FDA will have experts review formulae of products and issue permits if formulae are considered safe. Overseas onsite inspection is not required for a temporary permit.

Situation	Registration of overseas infant formula manufacturer	Registration （or filing） of formula	Need to apply for temporary access permit?	Approach
1	√/—*	√	×	Normal
2	√	×	√	Exhibition (CBEC)
3	×	√	√	Exhibition (CBEC)
4	×/—	×	√	Exhibition (CBEC)

*health food is not required for registration of overseas manufacturer.

Temporary permit only let manufacturers have their own exhibition where consumers can order products via CBEC platforms, but are not allowed to buy, pick up, or try goods on site.