Custom clearance documentation preparation, trademark registration, packing, labeling, and shipping
Documentation preparation
China has strict and complex documentation requirements for most food products imported into the country.
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。
For meat and meat products, the exporter may prepare the following documents to import products into China:
Commercial invoice;
A detailed packaging list;
Bill of lading;
Certificate for export from country of origin;
Hygiene/health certificate;
Certificate of no wood packing;
Trade contract with the importer; and
Sample of original label and Chinese label.
With the spread of COVID-19 in some countries, according to a circular released by the State Council on July 23, 2020 – meat processing enterprises shall properly handle the self-inspection and testing, establish and improve the whole-process traceability mechanism, and strictly prohibit the processing of livestock and poultry meat that does not conform to the provisions on animal quarantine or food safety standards.
In addition to documentation required for custom clearance, imported livestock, poultry, and meat products shall have the Nucleic Acid Test Qualification Certificate before entering the plant for processing. Clean and disinfect the transportation area, means of transportation, outer packing of goods and other related articles and utensils.
However, the circular does not specify whose responsibility it is to apply for the Nucleic acid Test Qualification Certificate. In practice, exporters are suggested to make it clear with their importers when signing the contract.
Trademark registration
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. 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.
Packing and labeling
If the meat products are pre-packaged, then the packaging must be toxic-free and resilient so that the product is sealed even when subject to later customs inspection.
Meat and meat products imported into China must be labeled properly to complete the customs clearance. There are several rules specifying the labeling requirements on layout and content of food in China. Some of these include:
Label rules for pre-packaged food (GB7718-2011, English and Chinese versions available here);
Label rules for pre-packaged food for special dietary uses (GB 13432-2013); and
Label rules for pre-packaged food’s nutritional labeling (GB28050-2011).
To be more specific, information in the below table should be included in relevant tables:
Shipping
Similar to other countries, China requires that the storage and transportation of meat products should be carried out under appropriate temperature conditions. For example, the central temperature of frozen poultry meat should not be higher than -15℃.
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When the goods are loaded onto the container, lead seals approved by the competent authority shall be applied. The seal number shall be indicated in the attached official veterinary health certificate. The package cannot be opened or changed the during transportation.
To be noted, China requires the exporter to inform its custom in charge before the shipment to ensure the traceability of meat products.
Quarantine inspection and customs clearance
After the products are shipped to the designated meat port and inspection filed, it is followed by a quarantine inspection procedure before the clearance, which is conducted by the customs officials. This is a consequence of the institutional reform implemented in 2018.
The imported meat products that pass inspection will be issued with a certificate by the GAC. This certificate is issued for every shipment of product.
If the imported meat products fail the inspection, the products will be sent back or destroyed. There are also chances to fix the non-compliance where the issues are minor (not affecting personal safety, health, or environmental standards). Technical remedies will be allowed under the supervision of the customs authority before the second inspection.
Following the inspection, the documentation and certification acquired by exporters and importers will be submitted to the customs for clearance. After that, the product will be allowed to enter China for manufacture, processing, sale, and use.
With the pandemic still ongoing, it has been reported that China’s customs are paying closer attention to COVID-19 surveillance on cold chain food from overseas nations after several positive COVID-19 tests were found on the packaging of cold chain food imports. The bottom line therefore is that the quarantine inspections and custom clearance review in China will be de facto much stricter – even though the general procedures are the same.
Looking forward
Meat products have always been under higher scrutiny in the import and export process due to food safety and quarantine considerations even before the outbreak of the COVID-19.
With the pandemic still rampant globally, China is endeavoring to secure its current hard-won anti-epidemic achievements by all means. It should therefore cause no surprise that the supervision and control on meat imports will be very strict in each step of the importation. There will not be much room for compromise in the foreseeable future as well.
Exporters are suggested to get used to this new normal and pay double attention to the quality of their meat products and COVID-19 prevention measures from the very beginning, if they do not want to get blacklisted by China customs or lose access to this ever-growing market in China.
Source：china-briefing
