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Summary of Common Problems Faced During Implementation of China Food Production Licensing System

  •   15 Jun 2017
  •    Rachel Shen
  • 979
  • Abstract: The common problems faced during the implementation of “Administrative Measures of Food Production Licensing” are addressed by CFDA in detail.

The “Administrative Measures of Food Production Licensing” went into effect on Oct. 1, 2015 (see CL news report on Sep. 2, 2015). Recently, China CFDA clarified relevant issues regarding the implementation of this regulation during the recent two years, which are summarized in Q&A format in this article.

Q1. How will external warehouse be supervised?

A1: The external warehouse should be under the regular supervision of local FDAs, with special focus on external warehouses where food raw and auxiliary materials are stored.

Q2. How will products that have not been included into “Classified Categories for Food Production Licensing” be examined?

A2: CFDA has released the “Classified Categories for Food Production Licensing”, which includes 31 large food categories and food additives which are subdivided into food additive, food flavor and compounded food additive (please click here for more details). Products that do not fall into any of these categories should be examined according to products with similar properties, technological characteristics and production requirements.

Q3. Should the executive standard be mentioned in the food production license?

A3: No.

Q4. What will happen if an application for production license renewal is not made within the stipulated deadline?

A4: It is stipulated in “Administrative Measures of Food Production Licensing” that the application for renewal of food production license should be made 30 working days before the expiration date. If not, a new food production license should be reapplied for. If the food production license is not approved before the expiration date, production should be halted until relevant approval is granted.

Q5 Should the production license have a “QS” mark or an “SC” mark?

A5: Manufacturers who obtained food production license before Oct. 1, 2015 with the “QS” or “XK” must change their license and use the “SC” mark before Oct. 1, 2018. Original packages and labels with “QS” mark should not be used after Oct. 1, 2018.

Q6. What supervision protocols should an enterprise follow if it resumes production after a long production hiatus?

A6: It should be reported to food and drug administration department for regular supervision if an enterprise resumes production after a hiatus of more than half a year.

Reference link

China CFDA No. 53 (2017) Announcement