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On April 13, 2021, China’s GAC authority issued the new version of the “Administrative Provisions on Registration of Overseas Manufacturers of Imported Foods”(Decree Order No. 248), which will come into effect on January 1, 2022. (Check ChemLinked Regulatory Database for history versions and E-translation.) View more at ChemLinked online course: The Ultimate Guide to China's GACC Overseas Food Manufacturer Registration.
Major Revisions Compared to the 2012 Version
1. The applicable scope is expanded to all food categories.
Before the release of this version, only four types of products (namely, aquatic products, dairy products, meat, and birds nest) are subjected to the overseas food manufacturer registration. But now, as revealed by Article 2 and 4, the application scope is expanded to all food categories, excluding food additives and food related products.
2. Manufacturers dealing with specific food categories can apply for the registration by themselves.
Apart from the recommendation from the competent authority in exporting countries, this new regulation now newly allows the individual application from certain manufacturers. Requirements of documents are specified as well. Details are explained as below.
Method 1 Recommendation from the competent authority in exporting countries | Method 2 Individual application from manufacturers | |
| Food categories | Meat and meat products, casing, aquatic products, dairy products, bird's nest and bird's nest products, bee products, eggs and egg products, edible oils and fats, stuffed pasta, edible cereals, industrial products of cereal flour and malt, preserved and dehydrated vegetables and dried beans, seasonings, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, special dietary foods, health food | Except for the food categories listed in Method 1. |
| Required documents | (Revised) (submitted by the competent authority in exporting countries) • Recommendation letter • A list of recommended enterprises and their application forms • Identity certificate, e.g. business license • A declaration that the enterprises meet the requirements in this regulation • A review report issued by the competent authority in exporting country | (Newly added) • Application form • Identity certificate, e.g. business license • A commitment declaration that the enterprises meet the requirements in this regulation |
*Note: China’s GAC is eligible to adjust the registration method and application materials of certain food categories based on the risk analysis of ingredient source, manufacturing technique, history data of food safety, consumption group, ways of eating, etc.
3. Video inspection is introduced to accelerate manufacturer registration.
GAC will carry out the review by themselves or by entrusting other agencies. Possible inspection forms include the document review, video inspection, on-site inspection, etc..
4. It is mandatory to label manufacturer’s registration No. on inner package of products.
According to Article 15, manufacturer’s registration No. is required to be labeled on both the outer and inner product packages.
5. Administrative rules related to alteration/renewal registration, revocation of registration and validity term are revised.
For manufacturers applying for the renewal registration, they shall submit the application 3-6 months before the expiration of the registration period.
Application materials for alteration are newly specified.
GAC can revoke the registration when applicants refused to assist GAC’s re-examination and accident investigation.
The manufacturer registration validity term is changed from “4 years” to “5 years”.
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