On June 24, 2015, an internal conference was held within the national inspection and quarantine department and several cross border ecommerce giants in Hangzhou to discuss the regulations on foods and cosmetics traded through cross border e-commerce. It is still unclear if the regulations listed below will be officially implemented as the new requirements will impose severly restrictive compliance requirements and likely have a massive impact on the fast development of this financially important sector. China has a long history of scandal and AQSIQ is tasked with ensuring the integrity of food imported into China and are worried that deregulating this sector is inviting disaster.
1. A “Negative list” management system for food and cosmetics traded on crossborder e-commerce platforms will be established by AQSIQ.
2. The commodities listed into the “Catalogue for the Implementation of Registration of Foreign Enterprises Producing Imported Food” should be from registered manufacturers audited and approved by CNCA. Health foods, cosmetics, GMO foods, and new food raw materials should be registered or filed with relevant departments before importation, and relevant safety assessment should be made. Infant formula should be subject to all the provisions outlined within the Food Safety Law and relevant AQSIQ regulations. Animal and plant inspection and quarantine certificates should be obtained before entry if relevant.
3. For enterprises operating an overseas ecommerce platform registered abroad, a domestic qualified enterprise should be entrusted to take relevant legal liabilities.
4. E-commerce traders should keep records with inspection and quarantine departments through the cross border ecommerce public information service platform. Overseas traders should entrust their domestic agents to handle this issue.
5. All products sold through cross-border e-commerce must be declared for approval by inspection and quarantine department through a cross border ecommerce public information service platform recognized by AQSIQ.
Enterprises are required to submit the following materials for declaration: 1) HS code, specifications and models; 2) official quarantine (health) certificates of the exporting country; 3) quality safety evaluation report or declaration; 4) electronic version of Chinese label and alerting information; 5) enterprise filing number
6. Imported foods and cosmetics should be accompanied by Chinese label and directions for use, which can either be in paper or published through e-commerce platform in Chinese in terms of product description, etc.
7. Cross border ecommerce traders should submit a self-inspection report for products imported for the first time. For high risk products self-inspection reports should be submitted for each batch of products.
8. Whole process traceability systems for imported foods and cosmetics should be established to truthfully record the health certificate number, product name, specifications, quantity, production date, shelf life, manufacturer, exporter, name/contact info of the consignee, delivery date, etc.
9. Commodities with quality defects should be recalled and relevant rectification measures should be taken. All defects should be reported to inspection and quarantine departments.
10. Inspection and quarantine departments should implement entry quarantine for every batch of imported foods. 5% of all low risk products will be sampled for laboratory testing, 10% of all medium risk products will be sampled for laboratory testing, and 20% of all high risk products will be sampled for laboratory testing. An importer conformity certification should also be obtained.
11. Any products found incompliant with Chinese national standards will be recalled and relevant enterprises will be notified.
12. Inspection and quarantine departments will implement intensified inspection methods and batch-by-batch release for foods and cosmetics traded through cross border ecommerce to improve the overall efficiency of customs clearance etc.
13. Animal and plant derived foods imported without prior quarantine permits can receive prioritized risk analysis to accelerate the entry process after specific application is received.
14. Inspection and quarantine departments will establish a whole process traceability information database for imported foods and cosmetics within their own administrative region.
15. Cross-border ecommerce products that do not comply with this regulation will be included into a negative list and subject to stricter inspection or prohibition on subsequent import.
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