On Sep. 23, General Administration of Customs (GAC) released list of 319 food and cosmetics importers which have poor customs clearance track records marred by product safety and compliance violations from 2015 to 2019.[1]
China’s risk warning and response mechanism is based on a system which requires serial violators which have accrued several product compliance or safety violations to be managed in proportion to the severity and total number of violations. Increased compliance requirements for those enterprises can include mandatory submission of testing reports or certificates for designated food categories.
Import Entities in Risk Warning List Face Stricter Clearance Requirements
According to the Administrative Rules on Import Entities with Poor Track Record drafted by former AQSIQ, overseas food manufacturers, exporters, domestic importers would be subject to more stringent supervision if their food products exported/imported into China are found to be substandard on two or more occasions (refer to Figure 1). GAC, which took over duties previously designated to the now disbanded AQSIQ is now responsible for managing the list and assigning proportionate supervision and enforcement.[2]
| Conditions for risk alert | Additionally required documentation for import next time | |||
| Type of non-compliant items | Varieties of products | Varieties of non-compliant items | Non-compliant batches | |
| Sanitary item | 1 | 1 | ≥2 | test report required for all non-compliant items |
| 1 | ≥2 | ≥4 | test report required for all items of the non-compliant product | |
| ≥2 | ≥2 | ≥8 | test report required for all items and all products | |
| Non-sanitary item | 1 | 1 | ≥3 | test report/supporting materials required for non-compliant items |
| 1 | ≥2 | ≥6 | test report/supporting materials required for all items of the non-compliant product | |
| ≥2 | ≥2 | ≥12 | test report/supporting materials required for all items and all products | |
| Other safety risks | test report/supporting materials required for designated items | |||
*Note:
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Frequent violations may trigger measures on all foods from that country
The Administrative Rules also include a mechanism to increase compliance requirements at a country level. A minimum of 6 enterprises and 16 batches of foods with poor record could trigger higher barriers against food imported from the country/region of origin. The conditions for risk alert on the exporting country are as follows.
| Conditions for risk alert | Reference responding measures (additionally required documentation) | ||||
| Type of non-compliant items | Number of enterprises | Number of non-compliant categories | Varieties of non-compliant items | Non-compliant batches | |
| Sanitary item | ≥2 | 1 | 1 | ≥16 | test reports required for all non-compliant items within that food category associated with compliance violations from that exporting country |
| ≥2 | 1 | ≥2 | ≥32 | test report required for all items (as stipulated in national standards) of the food categories associated with compliance violations from that exporting country | |
| Non-sanitary item | ≥2 | 1 | 1 | ≥24 | Relevant credentials and test reports required for all non-compliant items of the food categories associated with compliance violations for that exporting country |
| ≥2 | 1 | ≥2 | ≥48 | Relevant credentials and test reports (as stipulated in national standards) required for all non-compliant items of the food categories associated with compliance violations for that exporting country | |
| Other safety risks | test report/supporting materials required for designated items of certain products. | ||||
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