National food safety standard systems provide the backbone for supervision of wine products in China. In 1984 the former Department of Light Industry released QB 921-84 Wines and Their Test Methods, the implementation marked the beginning of standardized manufacture of wines in China. From 1994 to 2004, the industry standard “QB/T 1980-1994 Half Base Wine” left a regulatory loophole open allowing manufacture of blended wines with chemical components. The market chaos caused by this oversight didn’t end until 1st Jul 2004 when blended wines were officially banned. Following this China began more reform of wine-related standards and rules, including the drafting of new standards and provisions. In 2013 former NHFPC (now NHC) was created and replaced the former Ministry of Health.After institutional reform in 2018, National Health Commission (NHC) replaced NHFPC and is responsible for setting national food safety standards in accordance with provisions in Food Safety Law.
Part 1 The growing demands for imported wines
China is one of the world’s most promising emerging wine markets. As a result of the booming Chinese economy recent years have witnessed an explosive expansion in the demand for imported wines.
In the past domestic brands such as Changyu, the Great Wall and Dynasty have accounted for around 90% of total domestic wine sales. The historically poor market share occupied by imported wines was partly due to Chinese consumers’ unfamiliarity with foreign brands and also associated with the inherent lack of wine drinking culture in China.
Globalization has caused a massive transformation in the Chinese consumer mindset. Chinese consumers are increasingly looking for high quality imported wines. This demand coupled with a change in drinking habits amongst the younger generations has provided fertile ground for growth in the imported wine sector. Wine-drinking has taken root in the more developed east of China where the upwardly mobile middle-class is seeking alternatives to their more traditional upbringings. France remains the dominant exporter with a market share of 35.7% of all imported wines in China as per the data from 2013 while Australia and Chile as new world wine makers are quickly gaining ground.
Recently the Chinese government has launched a new initiative aimed at strictly controlling government expenditure on receptions, vehicles and overseas trips, also known as “the three public consumptions”. Since its implementation the reduction of superfluous spending has been accompanied with declines in sales of a range of products including imported wines. This move has had a significant impact on high-end wine sales as previously governmental purchasing represented a significant proportion of total sales. Considering that growing interests among domestic consumers the future prospects of imported wines especially table wines are extremely bright despite the recent government anti-corruption reforms.
In view of the treaty with the World Trade Organization, import tariffs of agricultural products (wine products contained) in China shall be cut below 5% before 2015 when the extended transitional period of 15 years will come to an end. With costing reduced, imported wines will be more competitive than ever before.
Part 2 China’s regulations and standards for wines
Most regulations overseeing the importation of alcoholic beverages generally apply to that of wines. In addition, there are also some specific regulations and standards made regarding the manufacture, procurement, sales and other aspects of wines.
Before QB/T 1980-1994 Half Base Wine expired on 1 Jul 2004, water-blended fruit wines were permitted for sale in China and could be labeled wine. After the standard was repealed China began a widespread reform campaign targeting relevant standards and regulations bringing about a well supervised regulatory system backed by sound legislation.
Major Wine Regulations Effective in China
|President Order 21 of 2015||Food Safety Law《食品安全法》||2015/10/01||The law at the top of all food-related regulations|
|former AQSIQ Order 144 of 2011||Measures for Administration of Imported/Exported Food Safety 《进出口食品安全管理办法》||2012/3/1|
|former CFDA Order 16 of 2015||Measures for Administration of Food Production Licensing 《食品生产许可管理办法》||2015/10/01||The basis that requires all food producers in China to procure a production license|
|former AQSIQ Order 27 of 2012||Administrative Provisions on Inspections and Supervisions of Labeling of Imported/Exported Pre-packaged Foods 《进出口预包装食品标签检验监督管理规定》||2012/6/1||The general provisions on labeling that all pre-packaged foods should conform to|
|former AQSIQ Order 55 of 2012||Administrative Provisions on Filing of Importers and Exporters of Imported Foods 《进口食品进出口商备案管理规定》||2012/10/1|
|former AQSIQ Order 55 of 2012||Administrative Provisions on Recording of Import and Marketing of Imported Foods 《食品进口记录和销售记录管理规定》||2012/10/1||Management in the stage of domestic circulation, mainly on the consignee part|
|MOC Order 25 of 2005||Measures for Administration of Alcohol Circulation 《酒类流通管理办法》||2006/1/1|
|Measures for Administration of Imported Alcohol in Domestic Market 《进口酒类国内市场管理办法》||1997/9/9||Promulgated by the State Economic and Trade Commission, the State Administration for Industry and Commerce, the Customs General Administration, the State Bureau of Technical Supervision, the Ministry of Public Health, and the State Administration of Import and Export Commodities Inspection|
|former SAIC Order 39 of 1995||Administrative Measures on Adverting of Alcohol 《酒类广告管理办法》||1996/1/1|
|former AQSIQ Notice on Dec 23 2004||Rules for Inspection on Production Licensing of Wines and Fruit Wines 《葡萄酒及果酒生产许可证审查细则》||2005/1/1|
|former AQSIQ Order 78 of 2005||Geographical Indication Product Protection Regulation 《地理标志产品保护规定》||2005/7/15||Champaign(2013), Bordeaux(2014), Napa Valley NV(2013)|
Measures for Administration of Alcohol Circulation, 2005 merely serves as a departmental regulation promulgated by the Department of Commerce. The associated legal obligations are rather weak in comparison to the rest of the legal hierarchy governing wines. The revised version of Measures for Administration of Alcohol Circulation, 2012 yet to come into effect includes several amendments but is still inadequate to provide an effective and comprehensive national administrative regulation for alcohol. Several provinces and cities have already had localized alcohol administrative regulations implemented, which have successfully stimulated the smooth development of regional alcohol industry. There is no lack of comparable precedents since overarching regulations for other special foods like dairy, genetically modified foods and salt have been formulated. Article 101 of Food Safety Law has already laid a legislative keystone for construction of a stable alcohol administrative and legislative system. (The Law shall be applied to the safety management of dairy, genetically modified foods, raw pork, alcohol and edible salt, except as otherwise stipulated, Article 101, Food Safety Law)
Since Geographical Indication Product Protection Regulation became effective in 2005, Champaign, Bordeaux, NAPA VALLEY NV and several other terms have gained geographical protection in China. This regulation is quite linked to similar regulations like EU’s Protected Designations of Origin (PDOs), and will help reduce the number of counterfeit products in the Chinese market.
Mandatory National Standards for Wines
|Product Standard||GB 15037-2006 Wines 葡萄酒|
|2008/1/1||Dictating the terms and definitions, product classification, requirements, analytical methods, inspection rules and labeling, package, transportation, storage of wines|
|Product Standard||GB 2758-2012 Fermented Alcoholic Beverages and Their Integrated Alcoholic Beverages 发酵酒及其配制酒||2013/2/1||Outlining general standards for fermented alcoholic beverages and their integrated alcoholic beverages, including terms and definitions, technical requirements and labeling|
|Labeling Standard||GB 7718-2011 General Standard for The Labeling of Prepackaged foods 预包装食品标签通则||2012/4/20||Outlining general requirements of all kinds of pre-packaged foods including wines, the content involves ingredients, date of manufacture, date of maximum durability, specifications, etc.|
|Labeling Standard||GB 10344-2005 General Standard for The Labeling of Prepackaged Alcoholic Beverage 预包装饮料酒标签通则||2006/10/1||Drafted in line with GB 7718-2011|
|Health Standard||GB 2760-2014 Standard for Usage of Food Additives食品添加剂使用标准||2015/5/24||Specifying using rules of food additives, allowed types of food additives, application scope, maximum levels of usage and residue|
|Health Standard||GB 2761-2011 Maximum Levels of Mycotoxins in Foods 食品中真菌毒素限量||2011/10/20||This standard includes lists of maximum levels of mycotoxins in foods, among which is the maximum level of palutin in alcoholic products including wines|
|Health Standard||GB 2762-2012 Maximum Levels of Pollutants in Foods 食品中污染物限量||2012/6/1||This standard specifies maximum amounts of lead in alcoholic products including wines|
|Health Standard||GB 2763-2014 Maximum Levels of Pesticides in Foods 食品中农药最大残留限量||2013/3/1||Manufacturers of wines refer to this standard for the maximum levels of pesticides in grapes|
|Production Standard||GB 12696-1990 Hygienic Specifications of Factories for Wine 葡萄酒厂卫生规范||1991/10/1||This standard specifies requirements of wine factories, especially applicable to bulk imported wine process|
Recommended Standards for Wines
|Analytical Standard (Recommended Standard)||GB/T 15038-2006 Analytical Methods of Wine and Fruit Wine 葡萄酒、果酒通用分析方法||2008/1/1||Outlining sensory, physical and chemical analytical methods of wine and fruit wine|
|Production Standard (Recommended Standard)||GB/T 23543-2009 Good Manufacturing Practice for Wine Enterprises 葡萄酒企业良好生产规范||2009/12/1||GMP for producing wines in China|
|Recommended standard||Norm of Terminology Translation of Imported Wines 进口葡萄酒相关术语翻译规范||2015/09/01|
|Draft||Measures for Administration of Alcohol Circulation (Revision) 酒类流通管理办法（修订）（征求意见稿）||Ministry of Commerce||Based on the 2005 version, the new draft will stipulate the record-filing of business operators and traceability, and will penalize the act of selling alcohol beverages to the underage|
Part 3 Competent authority
General Administration of Customs (GAC)'s main supervisory scope is the import and export inspection of wines.
National Health Commission (NHC) holds the obligation of drafting and releasing national standards related to wines.
*China has undergone department restructure in 2018. If you are confused about the competent authorities, please click here to read more.
Part 4 Tips on wine export to China
There are several checkpoints that wine exporters, agents and importers should pay attention to when trading wines in China.
The filing of exporters or agents with GAC
According to Administrative Provisions on Filing of Importers and Exporters of Imported Foods (former AQSIQ Order 55 of 2012), overseas exporters or agents shall fulfill record filing obligations with GAC through the filing management system (http://ire.eciq.cn) prior to exportation. The application form for filing should be submitted through the online platform with information such as authentic names of the exporter or agent, country/region, address, contact person, phone number provided.
After submitting the application form, exporters or agents will receive a file number and an inquiry number produced by the filing management system and with these numbers they can check their filing proceeding status and amend filing information.
The filing of importers or domestic agents with GAC
Consignees (importers or domestic agents) shall apply for filing at local industry and commerce department; the documents required may vary in different ports but in general are required as follows:
- An accurately completed application form for consignee filing
- A copy of industry and commerce business license, organization code certificate, identification paper of the legal representative, registration form for the filing and recording of foreign trade operators, with the original submitted for verification at the same time
- Documents on the quality and safety management system of the enterprise
- Documents on organization structure, department functions and job responsibilities concerning food safety
- Documents on planned food category of operation and storage location
- Explanations, including the food category and quantity, reporting on the last two years’ history of food importing, processing and marketing
Similar to exporter filing, consignees need also fill and submit the application form through the filing management system (http://ire.eciq.cn) and obtain a filing number.
After products are imported, importers must keep the import and sales information on record for a minimum of 2 years for future reference. Detailed information includes filing documents of imported record, product supply chain, complaint/recall record, filing documents of sales record.
The filing of labels of wines (former AQSIQ Notice No. 59 of 2011)
From 1 June 2011 former AQSIQ implemented the prepackaged food labeling management system. For wines imported for the first time, importers shall submit required documents to GAC for compliance verification. An IT then automatically generates a filing number for all qualified products. Upon re-importation, products with an existing filing number can forgo extended inspection of Chinese label (subject to permission from GAC).
Documents required may vary from different ports but in general are as follows:
- Paper copy of Chinese label and attachment of specific information (which should include the name of manufacturer, Chinese name of the brand, physical contrast, etc.)
- Electronic copy of Chinese label (which should be generated via the software “Aided Input Tool for Label Management System”
- A copy of original label and translation (which can be skipped provided that the label in Chinese rather than in other languages has been attached at arrival to the port). On condition that ingredients and food additives have not been comprehensively listed on the original label, a complete ingredient list of both English and Chinese shall be submitted separately
- In case that certain contents such as award-winning, certificate-wining, AOC and geographical indication are highlighted in the label, corresponding certificate and translation shall be provided.
USA’s wine export certificate (applicable to US wines only)
As was agreed with the US competent authorities, General Administration of Customs and former AQSIQ jointly announced that since 1 Mar 2014 a wine export certificate will be used as a multi-purpose certificate for wine products exported to China. Hence Certificate of Origin, Certificate of Health Sanitation or Certificate of Authenticity/Free Sale will no longer be issued from US authorities for the Chinese wine market. (Notice No. 164, 2013 of AQSIQ and GAC)
Part 5 Requirements of labeling in Chinese
Imported wines in China require back labels in simplified Chinese corresponding to original labels and products attached prior to market circulation. There are two options: use label stickers placed on top of the original labels before the batch of wines is exported to China or conduct the process at port/bonded area. Either way requires label filing with GAC and compliance check after arrival.
According to GB 15037-2006 Grapes, GB 7718-2011 General Standard for The Labeling of Prepackaged foods, GB 10344-2005 General Standard for The Labeling of Prepackaged Alcoholic Beverage and Article 42 of Food Safety Law, information required on the labels of imported wines include: name, type and vintage of product, ingredients, alcohol content, country of origin, net content, manufacturer, name, address and contact of distributor, storage conditions, filing date and shelf life, food additives, barcode, etc.
figure1: China wine compliance flow
Information such as country of origin, filing date shall be consistent with documents provided by the exporter or overseas agent. Filling dates require certificates of bottling dates provided by producers.
Food additives must be shown on the label. Sulfur dioxide is the most commonly used food additive in wines. If other food additives are used the labeling of these food additives shall be in line with requirements in GB 2760-2011 Standard for Usage of Food Additives.
If specific information outlining awards and accolades are included certificates and other valid proof shall be submitted for check.
In accordance with GB 7718-2011, the health warning “过度饮酒有害健康”, which means excessive drinking will harm your health, shall be presented on the label.
On condition that the original label is not fully covered by the Chinese one, the foreign language content exposed shall be translated and presented on the Chinese label.
Part 6 Tariffs
High tariffs have been imposed on imported wines in China which in turn will raise the retail prices. In general, the tariffs of bottled wines are as follow:
Import tariff: Tariff rate of wines for most favored nations have been lowered from 43% to 14% since 2005. CIF x 14%
VAT (value added tax) tariff: 17%. (CIF + tariff) x 17%)
Consumption tariff: 10% [(CIF + tariff)/ (1-10%)] x10%)
The sum total rate of tariffs for bottled wines should be 41%. VAT and consumption tariffs also apply to domestic wines.
It is notable that import tariffs can vary between countries. New Zealand has the advantage of Free Trade Agreements (FTA) meaning its import tariff rate for wine has been zero since 2012. Chile is also the beneficiary of FTA, and its import tariff rate is estimated to drop to zero in 2015 and is currently 1.4% (2014).
Import tariff rate of bottled wines for major wine exporting countries in China
|Country||Tariff rate as of 2015||FTA||Note|
|Australia||14||√||FTA officially signed on 17 Jun 2015|
|Chile||0||√||FTA initiated since 2006|
|New Zealand||0||√||FTA initiated since 2008|
For bulk wines of more than 2 liters per package the imported tariff rate is 20% (under MFN condition) provided single packaged products of less than 2 liters remains at 14%.
Part 7 Expert Article & Ebook