On December 14, China’s General Administration of Customs (GACC) issued a notice providing more information related to the new registration requirements for companies that export food to China.

The Notice, No.103 of 2021 (link in Chinese), is part of the implementation of the Provisions of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food and Measures of the People's Republic of China for the Administration of Import and Export Food Safety. According to the rules, all overseas manufacturers of foods that export to China are required to register with GACC. This registration requirement has raised concerns and criticism from trading partners, but nevertheless is set to take effect on January 1, 2022 as scheduled.

According to the December 14 notice, overseas food manufacturers can register their information on a dedicated website. All product categories, HS codes, and inspection and quarantine codes can be found on the website. The GACC also issued guidelines (link in Chinese) previously on required documents and procedures for registration of foreign food manufacturers.

Normally, food manufacturers can register directly through the registration system. However, the new provisions require companies that produce 18 designated categories of food, including meat and dairy products, to register through official recommendations of the country in which the companies are located. As a result, the overseas companies that produce these 18 categories of food can only obtain their registration account through the national/regional authority, according to the notice.

Once registered, the registration number for the company shall be included in the custom declaration forms in order to be cleared by Customs.

The notice also states that the food produced on or after January 1, 2022 shall meet the packaging and labelling requirements under the Measures for the Administration of Import and Export Food Safety. The current rules will continue to apply to food produced before January 1, 2022.

According to the China 2021 Report on Food Imports, China imported over 108 billion (link in Chinese) U.S. dollars of food in 2020, and for the first three quarters of 2021, China's food imports were 101.41 billion U.S. dollars, an increase of 29.8% compared to the same period last year.

Companies that sell products to China said they were expecting “major disruptions after Jan. 1” and some called the new registration requirement a “non-tariff trade barrier.”