China to Amend GACC Decree 248 on Registration of Overseas Manufacturers of Imported Foods

On January 3, 2025, the General Administration of Customs of China (GACC) released a revised draft of the Regulation on the Registration and Administration of Overseas Manufacturers of Imported Food. Compared to the current registration requirements, the draft introduces several significant changes. Stakeholders can submit their comments via email to [email protected] by February 19.

Background 

Since the implementation of the current regulation, known as GACC Decree 248, on January 1, 2022, over 90,000 overseas food production enterprises from more than 170 countries and regions have obtained registration. Additionally, over 290 foreign regulatory authorities have used the registration system to recommend enterprises for export to China. The registration requirements and principles have been widely understood and actively supported by international stakeholders.

As China continues to expand its openness, the volume of imported food trade and the number of registration applications from overseas producers have surged. To ensure the safety of imported food while supporting foreign trade development, GACC has identified the need to refine the regulations based on practical challenges encountered during implementation.

Key Revisions 

1. Refinement of "System Recognition" Requirements 

The draft elaborates on the "system recognition" criteria, which are currently part of the registration conditions for overseas food producers. The revised draft introduces additional pathways for recognition, including cooperation agreements signed between GACC and foreign authorities, such as food safety agreements, Authorized Economic Operator (AEO) mutual recognition agreements, and other cooperative documents involving food safety. This enhancement aims to promote international co-governance by recognizing the outcomes of foreign food safety management systems.

2. Introduction of New Registration Methods 

The draft proposes a new registration approach linking manufacturer registration with system recognition at the national or regional level. For countries or regions with GACC system recognition, their competent authorities may submit a list of recommended enterprises to GACC, which will then register the listed enterprises and assign them a registration number. GACC reserves the right to conduct random inspections of recommended enterprises.

For enterprises from countries or regions without system recognition, they must apply for registration directly or through an agent. The required materials vary depending on the food category. For products listed in the revised Catalog of Foods Requiring Official Recommendation Letters, enterprises must submit additional documents, such as inspection reports and recommendation letters from their competent authorities, consistent with current requirements. The draft also replaces the term "legal representative" with "actual controller (company)" in the application information requirements.

3. New Catalog for Recommended Registration 

The draft introduces a revised Catalog that includes 11 categories of food subject to recommended registration: meat and meat products, casings, bird's nest and bird's nest products, eggs and egg products, stuffed pasta, rice (newly listed), grain milling products and malt, nuts and seeds, dried fruits, dairy products, and aquatic products. Meanwhile, certain categories currently subject to recommended registration, such as bee products, edible oils and oilseeds, grains (excluding rice), fresh and dehydrated vegetables, dried beans, condiments, unroasted coffee and cocoa beans, special dietary foods, and health foods, may no longer require recommended registration, significantly simplifying registration procedures.

4. Adjustments to Re-registration Requirements 

The draft clarifies the conditions for re-registration, moving away from a one-size-fits-all approach. Changes such as relocation of production facilities, changes in legal representatives, or alterations in registration numbers granted by foreign authorities will no longer automatically trigger re-registration. Instead, re-registration will only be required for changes that significantly impact food safety and hygiene management, aligning with the overarching goal of ensuring imported food safety.

5. Removal of Time Limits for Renewal Applications 

The current regulation stipulates that overseas food producers must apply for registration renewal 3 to 6 months before the expiration of their registration. The draft removes this specific time limit, providing greater flexibility for enterprises.

6. Exemptions from Registration 

The draft explicitly exempts certain categories of food from registration requirements, including items sent via mail, express delivery, cross-border e-commerce retail, and those carried by travelers. Additionally, samples, gifts, donations, exhibits, aid, duty-free products, and food for official or personal use by foreign embassies and consulates in China are also exempt. This clarification addresses previous debates within the industry regarding the registration requirements for cross-border e-commerce and sample products, providing a definitive resolution.

Conclusion 

Once implemented, the revised draft is expected to significantly reduce the number of enterprises required to apply for registration. By simplifying registration pathways for overseas producers, the draft reflects GACC's efforts to strengthen cooperation with foreign regulatory authorities, recognize their oversight systems, and optimize registration processes.

The finalized version was published by GACC on October 14, 2025. For a more comprehensive interpretation of the new overseas food manufacturer registration policy, please register for ChemLinked's free webinar on May 7, 2026. Please feel free to contact us for any CIFER registration-related questions or registration supports.