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China’s Major Barriers for Importing Baby Formula

China has become the second largest baby food and infant formula market in the world only after USA and being at its golden age for consumption of baby formula. It is predicated that the number of newborns every year will exceed 17 million and the 0-3-year-old babies will maintain about 50 million in the next few years. With large population of babies and phenomenal buying momentum of Chinese people, the demand for imported infant formula is ever increasing.

However, the threshold for importation of milk powder for babies was elevated with the implementation of Administrative Measures on Inspection, Quarantine and Supervision of Import and Export Dairy Products (AQSIQ Order 152 of 2013). After a series of milk powder scandals, the Chinese regulator has determined to overhaul the domestic milk powder industry to recoup consumers’ trust and tightened control over imported baby formula by releasing the “Opinions on Further Intensifying Quality and Safety of Baby Milk Powder ” (see Chemlinked news on 28 Jun).

It is worth mentioning that quota management is applied to baby formula, according to the local CIQ official. Nevertheless, to get a certian amount of quota from local department of commerce is never an easy task for baby formula importers or consignees. Moreover, the AQSIQ Order 152 of 2013 requires registration of overseas food manufacturers before 1 May 2014 and the filing of exporters and importers.

Apart from those administrative trade barriers, the imported baby milk powder must be found in compliance with Chinese regulations and national food safety standards. Basically, the formula and label of baby milk powder should be designed specifically for the Chinese market, said the CIQ official. 

Imported baby formula must meet requirements specified in GB 10765-2010 Infant Formula (for babies of 0-12 months) and GB 10767-2010 Older Infants and Young Children Formula (for babies of 6-12 months and 12-36 months), in terms of sensory requirements, indicators of nutrients, optional components, limits of contaminants and mycotoxins as well as requirements for food additives and labeling. During port inspection, milk powder products with unsuitable formula, sub-standard labels or excessive microorganism or heavy metals, etc. will be rejected.

The inspection and quarantine could be extremely strict for most of the overseas companies, stated by the local CIQ officer. Every batch of infant formula is subject to random sampling at their entry into China. The sample selected will be sent to a food lab for testing which would last for over 1 month. Up to 60 testing items for a can of baby formula could be conducted. Therefore, overseas manufacturers should have a profound knowledge about details in the above two product standards to prepare milk powder especially for Chinese babies.

Overseas baby formula are mandated to have Chinese labels in accordance with English labels printed on the minimum sales packaging. Besides the content, the size of words on labels also matters. If it is too small, importers will be asked to update labels. Since lots to be considered, it is strongly recommended that prior to import, the consignee could send a sample label to a local CIQs for pre-review in case of any discrepancies. 

For comprehensive Chinese regulatory scheme for baby formula and steps to import, please refer to Chemlinked special report: China's Regulatory Environment for Baby Formulawhich mainly covers the following aspects:

  • Overall market analysis 

  • Regulatory framework of baby formula in China

  • National Food Safety Standards for baby formula

  • Latest Far-reaching Policies and updates 

  • Steps to exporting baby formula into China

  • Labeling requirements 

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