China became the world’s second largest buyer of imported food and beverage after the US in 2016. By 2019, there were 2,283 kinds of imported foods from 176 countries and regions incorporated into China’s market
Despite the lure of its huge market, exporting food to China is not easy. China has a multi-layered food regulatory system to ensure the quality and safety of imported goods. Each year, many foreign manufacturers and exporters fail to access the Chinese market due to insufficient procedure.
Here we will introduce some of the many certifications, regulations, and procedures required to export food products to China.
Step 1: Complete the importers and exporters registration
Foreign exporters usually adopt two ways to get goods to China: general trade export or cross-border e-commerce (CBEC).
In either model, all exporters and Chinese importers of foreign food must be recorded through the “Internet + customs platform” of General Administration of Customs of the People’s Republic of China (GACC).
In addition, for higher safety requirements, some of the products such as beef or baby formula are on the “List of Food Imports Subject to Enterprise Registration” , the foreign manufacturer need to register with the China’s Certification and Accreditation Administration (CNCA). The registration will be valid for four years and is extendable.
Step 2: Prepare documentation, pre-import licensing, and trademark registration
Documentation needed to clear customs
Before shipping the products, entities are required to submit properly documented information on quality, quarantine, origin, and import control, along with a detailed packaging list and a description of the packaging material, among other documents.
These documents are reviewed only after the shipment reaches China. Therefore, the entity must ensure that all documents are complete and authentic to avoid any delay and storage costs.
Entities can use the Harmonized System (HS) codes available on the China Customs’ website to check the category of the product, the associated import tax rates, documentation, licenses, and testing requirements (the HS nomenclature is the international system used for categorizing all products traded between countries).
Although the documentation requirements vary between products and product categories, the exporter may prepare the following documents to import food products into China:
· Commercial invoice;
· A detailed packaging list;
· Bill of lading;
· Certificate for export from country of origin;
· Hygiene/Health certificate;
· Certificate of bottling date (for drinks);
· Certificate of free sale;
· Sample of original label;
· Sample of Chinese label; and
· Inspection certificate issued by AQSIQ.
In general, food products entering China do not require pre-import licensing.
But if the product is included in the 2019 Goods Catalogue for Automatic Import License Management, such as poultry or dairy products, importers should apply for an Automatic Import License issued by the Ministry of Commerce (MOFCOM).
In addition, food items subject to import tariff quotas, such as wheat, corn, rice, and sugar are required to obtain the Agricultural Products Import Tariff Quotas Certificate.
Since China only acknowledges trademarks registered within its own jurisdiction and follows the first-to-file system, registering the trademark in China is a key step for a foreign entity to protect its brand.
This is necessary if the firm wishes to avoid trademark squatters and disputes with local counterfeiters, which can result in reputational damage, losing customers and revenue as well as time-consuming and costly adjudication.
Foreign companies are recommended to file trademark applications with the Trademark Office of National Intellectual Property Administration (CNIPA) through a register agent – if they do not have a residency or place of business in China.
Step 3: Labeling
Every food product imported in China must be labeled in simplified Chinese characters to complete the Customs clearance. There are several rules specifying the labeling requirements on layout and content of food and beverage in China. Some of these include:
· Label rules for pre-packaged food for special dietary uses (GB 13432-2013);
· Label rules for pre-packaged food’s nutritional labeling (GB28050-2011); and
· Label rules for pre-packaged alcoholic beverage (GB 10344-2005).
*GB refers to “Guo Biao” in Chinese here, meaning national standard.
In general, a label must provide the following:
· Standard name of foodstuff;
· List of ingredients as percentage;
· Name and address of manufacturers, local agent, or distributor;
· Production date, best before, end date, and guidance for storage;
· Country of origin;
· Quality grade;
· Code of national standard/industry standard for the production; and
· Special contents, if any.
All labels must be approved by the Chinese Inspection and Quarantine (CIQ) under AQSIQ. As label standards in China are subject to change, you are advised to consult experts to ensure compliance with the updated label requirements.
Step 4: CIQ, the food sanitary inspection, and customs clearance
Once the products reach China, the food products are inspected by Customs officials for review of relevant shipping documentation and labeling requirements.
The process is more complex for the first-time export. The procedure will be relaxed in the future after the first successful export.
Goods that pass customs clearance and inspection
The imported foods that pass inspection will be issued with a China Entry-Exit Inspection and Quarantine Bureau (CIQ) certificate by the GACC and be allowed to enter China. This certificate is issued for every shipment of product.
Goods without complete documentation
If the shipment misses any documents and Customs seizes it, the entity may either provide the missing documents or a CIQ declaration. To obtain a CIQ declaration, the entity must provide the following documents: business license, importing license, quota certificate, safety compliance declaration, an introduction to the company, and product information in detail.
Goods that fail customs clearance and inspection
Imported food that fails being cleared through Customs may undergo technical treatment under GACC supervision and then be re-inspected or be issued a Returns Handling Notice, meaning that the importer must return the product back to the exporter, or the goods have to be destroyed.
China offers many opportunities for global food exporters looking to enter a large and profitable market. However, the country’s food and beverage import process can be very hard to navigate for first time exporters, due to its fragmented and localized system.
In the other hand, China authorities are already realized such situation and start to simplify the regulations and procedures in recent years.
This article gives a general outline of process for exporting food to China. Exporters should also seek advice from competent consultancies and stay tune to the latest news of China policies. Food2China can provide information for both purposes. We wish your company’s success in one of the world’s largest consumer markets.
Source: Asia Briefing, Dezan Shira & Associates