China has a multi-layered food regulatory system to ensure the quality and safety of imported food items. Every year, however, a large amount of food imported into the country is either returned or destroyed due to lack of compliance or irregularity in food quality.
This causes a significant loss to both the importing and exporting companies. In times of greater transgression, the import license may be revoked and the companies may be barred from future trade.
Keeping in mind the high business risks involved, companies must stay abreast of the latest food regulations and ensure the conformity of the products to the necessary import procedures. In this article, Dezan Shira & Associates and the Silk Initiative will introduce some of the many certifications, regulations, and procedures required to export food products to China.
China’s regulatory environment
Regulations on import vary across types of food, and may not be consistently applied and enforced by different ports, bureaus, and individual officers. Therefore, companies are advised to allow for additional time and money to resolve unexpected issues and work closely with reliable partners.
Some of the common laws and regulations that companies must comply with are: the food safety law, the import and export commodity inspection law, the imported food importers and exporters filing regulations, and the imports and export animal and plant quarantine law, amongst others.
Step 1: Complete exporters and importers registration
As an overseas manufacturer and exporter of food, you must register with the State Certification and Accreditation Administration (CAA) if the food product being exported is on the ‘List of Food Imports Subject to Enterprise Registration’. Some of the food products that have heightened safety requirements such as meat and health products require additional registration. The registration is valid for 4 years and is extendable.
Moreover, as of October 2015, it is mandatory for exporters to register each shipment of food products online with the Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) department for tracking purposes.
Step 2: Complete documentation and pre-import licensing
China has strict and complex documentation requirements for the majority of food products imported into the country. Before the shipment of products, you are required to submit documents on products’ 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, you must ensure that all your documents are complete and authentic to avoid any delay and storage cost.
For ease of understanding, you may use the Harmonised System (HS) codes available on China Customs’ website to check your product category and 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, you 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
- Inspection certificate
In general, food products entering China do not require pre-import licensing. However, if you are importing poultry or dairy products, you need to obtain the Automatic Import License issued by the Ministry of Commerce. 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.
Step 3: Ensure label compliance
Every food product imported in China must be labelled in simplified Chinese characters to complete the Customs clearance. The general rules of the labelling of pre-packaged food, GB7718-2011, specifies the labelling requirements on layout and content of pre-packaged foods in China. In general, a label must provide following information:
- Standard name of foodstuff;
- List of ingredients as percentage;
- Name and address of manufactures, 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 Service (CIQS). As label standards in China are subject to change, you are advised to consult experts to ensure compliance with the updated label requirements.
Joel Bacall, Senior Client Manager of food and beverage brand consultancy the Silk Initiative, further remarks that ‘while you need to ensure your products labelling is compliant with Chinese regulations, you also need to consider how your products are packaged from a consumer and market perspective. For example, you will have to consider whether it’s best to cover existing packaging with a new label, as well as how your competitors are re-designing their labelling to gain a competitive edge with the consumers in the market.’
Step 4: CIQ food sanitary inspection and customs clearance
Once the shipment arrives in China, the food products are inspected by Customs officials for review of relevant shipping documentation and labelling requirements. The CIQ sanitary certificate is issued only if the documents are complete. This certificate is issued for every shipment of product.
If the shipment is missing any documents and custom seizes it, you may either provide a CIQ declaration or provide the missing documents. To obtain a CIQ declaration, you must provide the following documents: your business license, importing license, quota certificate, safety compliance declaration, an introduction to your company, and product information in detail.
If you are exporting food products for the first time, the process is more complex though the procedure is relaxed after successive exports. However, AQSIQ officials may still inspect labels and samples in the following shipments.
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: because of the country’s vast geography, export to different locations within China will require due diligence so as to avoid administrative failure. Following the steps outlined above can make the process smoother and more effective, and seeking advice from competent consultancies in the food and beverage space will ensure your company’s success in one of the world’s largest consumer markets.
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This article was co-authored by Dezan Shira & Associates and the Silk Initiative:
Dezan Shira is a full service practice in China, providing business intelligence, due diligence, legal, tax, IT, HR, payroll, and advisory services throughout the China and Asian region. For assistance with China business issues or investments into China, please contact them at firstname.lastname@example.org or visit www.dezshira.com.
The Silk Initiative is a business strategy and marketing mix innovation consultancy specializing in the food and beverage space. They provide a range of brand strategy, consumer insight, business intelligence and creative execution strategies to clients ranging from global food and beverage giants to SMEs. Need help making sense of the complexities of the China and Asia market? Contact them at email@example.com or visit www.thesilkinitiative.com.
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