Takehome:
During REACH24h’s China regulatory annual conference details related to the categories of foods that will be considered for manufacturer registration in the future, as well as different modes of inspection during the manufacturer registration for both general trade and CBEC mode were outlined.
Currently, overseas food manufacturers are required to be registered with China CNCA prior to market entry, including dairy products, meat, aquatic products, and cubilose products (birds nest) (please see the “Guidance on Registration of Overseas Food Manufacturers with China CNCA” in details).
Development trend for food categories that will require manufacturer registration:
Food category risk will be assigned based on the registration category and will include raw materials risk, consumption group risk and processing facility risks. From the aspect of raw materials, food categories with animal derived raw materials will be included into the registration scope, such as bee products, egg, etc. In terms of processing facilities, canned food is considered high risk and is likely being considered for manufacturer registration.
Overseas manufacturer registration is designed to ensure that overseas manufacturers exporting to China match use practices equivalent to Chinese national standards and the products or commodities they manufacture comply with the basic requirements of China’s food safety law and subordinate standards. Overseas manufacturers are generally evaluated in three different ways, which are field inspection (mostly for infant formula, meat and cubilose products), sampling inspection of manufacturers recommended by the exporting country (district) (mostly for dairy products excluding infant formula), and inspection conducted after approval of manufacturer registration (mostly for aquatic products).
Sampling inspection will also be conducted for manufacturers who have already registered successfully. The registration qualification of the manufacturers which fail sampling inspection will be suspended or even revoked under serious situations. Mr. Ye Zhiping, a former officer from CNCA Shanghai indicated during the summit that CBEC traded commodities will not be exempted from manufacturer registration obligations and will be the same as those traded through general trade channels.
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