Other BriefingsSelling Agricultural Products to China: Tighter Traceability and Compliance Rules from December 15
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Selling agricultural products to China now requires stricter oversight, as GAC Announcement No. 219 of 2025 significantly raises the bar for traceability and compliance, making accurate registration and comprehensive documentation mandatory for continued market access.
On November 7, 2025, China’s General Administration of Customs (GAC) released the Announcement on the Declaration and Management Requirements for Overseas Enterprises Exporting Agriculture Products to China (hereinafter, “GAC Announcement No. 219”), which will take effect on December 15, 2025.
The new regulation introduces clearer and more structured procedural requirements for the declaration and management of overseas enterprises involved in the export of agricultural products to China. It aims to strengthen traceability, enhance quarantine supervision, and improve the efficiency and consistency of customs clearance by aligning with international phytosanitary standards and China’s evolving regulatory framework for agricultural imports.
According to the GAC, the new system is grounded in the Law of the People’s Republic of China on the Entry and Exit Animal and Plant Quarantine and its implementing regulations. It requires both overseas exporters and Chinese importers to adhere to tighter information disclosure and registration verification processes.
This represents another significant step in China’s ongoing effort to reinforce food safety supervision, standardize enterprise registration, and advance the development of a more digital and transparent compliance environment for agricultural trade.
GAC Announcement No. 219 also serves as a timely entry point to examine how foreign agricultural producers and exporters can adapt to China’s import supervision system and better position themselves to leverage market opportunities while ensuring compliance with customs and quarantine procedures.
Understanding the new GAC requirements
Catalog of Agricultural Products Requiring Official Recommendation and Registration
A key element of GAC Announcement No. 219 is the introduction of a catalog system that defines which agricultural products require overseas official recommendation and registration before they can be exported to China. To determine which products fall under this system, the GAC will carry out quarantine risk assessments based on international phytosanitary standards and China’s own import supervision experience.
Products assessed as higher risk will be included in the Catalog of Agricultural Products Requiring Overseas Official Recommendation and Registration (in Chinese, 进境农产品需境外官方推荐注册登记目录). On November 10, 2025, the GAC released the initial version of this Catalog. It will be updated when needed and will serve as the main reference point for both overseas exporters and Chinese importers.
For businesses, the implications are straightforward:
- Exporters shipping items listed in the catalog must complete the required registration procedures through their home-country authorities before exporting to China; while
- Importers must ensure that any catalog-listed agricultural product they bring into China comes from an overseas enterprise that appears on the GAC’s list of registered entities and whose registration status is normal.
Verification of registered overseas enterprises
Once an overseas enterprise has completed the registration process, its information will appear in the GAC’s official databases. Importers and exporters can verify registration status through two channels:
- The List of Registered Overseas Enterprises for the Quarantine of Imported Animals and Plants and Their Products(进境动植物及其产品境外企业检疫注册登记名单), available on the GAC portal here; and
- The “Internet + Customs” system via the “I Want to Check” (in Chinese, 我要查) “Quarantine Information Inquiry” module, here.
These tools make it easy to confirm an enterprise’s Chinese registration number, its current status, and the scope of products it is approved to export. Checking this information before shipment is essential, as only enterprises with an active, normal registration status are permitted to ship catalog-listed agricultural products to China.
Import declaration requirements
When bringing catalog-listed agricultural products into China, importers must ensure that the overseas enterprise’s Chinese registration number is correctly entered during customs declaration.
The number must be filled in the “Product Qualification” (in Chinese, 产品资质) section of the Customs Declaration Form or the Filing List, under the certificate field for “Registration of Overseas Production, Processing, and Storage Enterprises for Imported Animals, Plants, and Related Products” (license category code 302).
If a declaration includes multiple product items, the importer must provide the corresponding registration number for each item. This item-by-item matching is crucial, as incorrect or missing information can disrupt traceability and trigger compliance checks.
Effective date and implementation
The new requirements will take effect on December 15, 2025. From that date onward, any import declaration that lacks valid or accurate registration information could face delays, additional inspection, or even rejection by customs.
By introducing clearer documentation rules and a unified registration framework, the GAC aims to improve customs efficiency and strengthen traceability for inbound agricultural products. The new mechanism helps ensure that all imported agricultural goods meet China’s quarantine and safety standards while reducing administrative ambiguity for both exporters and importers.
Why China is enhancing its regulatory approach to agricultural imports
Food safety and traceability as national priorities
China’s tightening of agricultural import controls is rooted in long-standing national priorities around food safety, risk prevention, and supply chain transparency. After a series of food safety incidents in the 2000s and 2010s, Chinese regulators began moving toward a risk-based, standards-driven import supervision model. This culminated in key institutional reforms, such as the adoption of Registration and Administration of Overseas Manufacturers of Imported Food (GAC Decree No. 248) and Administrative Measures on Import and Export Food Safety (GAC Decree No. 249) in 2022. Together, these measures required a wide range of foreign food processing and manufacturing enterprises to undergo unified registration with the GAC before shipping goods to China.
The new GAC announcement extends this regulatory logic further upstream, moving beyond processed food producers to encompass overseas agricultural enterprises involved in production, processing, or storage activities. Under the new framework, agricultural imports will be subject to phytosanitary risk assessment and classified into categories that require official recommendation and registration by the exporting country’s competent authority.
In effect, the new announcement broadens China’s food safety architecture from mid-stream processors to the primary agricultural supply chain, strengthening oversight at the point of origin and closing gaps in traceability that previously existed for raw agricultural products.
Expanding import volumes and diversified sources
China’s tightening of agricultural import supervision also reflects the scale and complexity of its import demand. As urbanization accelerates, household incomes rise, and dietary preferences evolve, Chinese consumers are purchasing more and a wider variety of foreign agricultural products.
This shift has been particularly evident in segments such as high-protein foods, fresh and dried fruits, dairy products, edible oils, and specialty crops that are not sufficiently produced domestically.
Against this backdrop, China’s agricultural imports have continued to expand. In 2024, the value of agricultural imports exceeded US$215 billion, underscoring China’s role as one of the world’s largest buyers of agricultural commodities. Major import categories included soybeans, grains, meat, dairy, fruits, nuts, and oilseed products, which together form the backbone of China’s food supply chain and animal feed industry. Demand for premium and higher-value agricultural goods has also grown, driven by rising consumer expectations for food quality, safety, and variety.
This expansion has been accompanied by a diversification of China’s import sources. Traditional suppliers such as the United States and Brazil continue to dominate bulk commodities like soybeans and meat. At the same time, ASEAN countries, Australia, New Zealand, and the European Union have strengthened their positions across various agricultural categories, reflecting China’s efforts to build a resilient and geographically distributed import network.
However, with rising import volumes and an increasingly complex supplier landscape, Chinese regulators face heightened challenges in ensuring consistent quality, sanitary compliance, and traceability. As a result, customs authorities have placed greater emphasis on standardized registration, clear documentation, and enterprise-level accountability, all of which underpin the new requirements introduced in the new GAC announcement.
What the new rules mean for businesses
The new compliance framework signals a shift toward stricter supply chain accountability. Importers can no longer rely solely on domestic customs paperwork. Instead, they must actively verify the credentials of overseas suppliers before any transaction. This means procurement teams need to integrate registration checks into their sourcing workflows, as failure to do so could lead to clearance delays, shipment rejection, or even enforcement penalties.
Meanwhile, administrative complexity will increase under the new rules. Customs declaration systems now require additional data fields, such as overseas enterprise registration numbers, which will demand updates to IT systems and staff training. Businesses should anticipate longer lead times for documentation and factor this into their logistics planning.
Supply chain flexibility may also be tested. Companies will need to monitor GAC’s catalogue updates continuously and adjust sourcing strategies if a supplier loses compliance status. This could involve diversifying supplier bases or negotiating contingency arrangements to avoid disruptions.
Finally, the emphasis on traceability and chain-of-custody suggests that regulators will scrutinize origin documentation and supply chain integrity more closely. Businesses should expect tighter audits and prepare by strengthening internal compliance systems, improving data accuracy, and maintaining robust evidence trails.
With the effective date approaching, companies should act immediately: audit current suppliers, verify registration status, update declaration procedures, and ensure customs filings are complete and accurate. Early action will reduce risk and maintain uninterrupted market access.
Compliance pathway for overseas exporters
Navigating the new requirements under the latest GAC announcement will require overseas agricultural producers and exporters to adopt a structured compliance approach. The following steps outline how foreign enterprises can prepare for registration, documentation, and coordination with Chinese partners to ensure smooth customs clearance once the new rules take effect.
1. Identify product category and regulatory requirements
The first step for any exporter is to determine whether their agricultural products fall under the mandatory registration and recommendation regime. The published initial version of the GAC catalog of agricultural products requiring overseas registration will specify which categories (such as grains, meat, fruits, dairy, nuts, or other raw and semi-processed goods) must undergo official recommendation by the competent authority in the exporting country.
Exporters should carefully review this catalog and any related guidance, as sector-specific supervision protocols may apply. Products with higher phytosanitary or biosafety risks will likely be subject to stricter entry requirements and enhanced documentation.
2. Coordinate with competent authorities in the country of origin
For products included in the GAC catalog, registration must be carried out through the exporter’s national competent authority, which may include the Ministry of Agriculture, national food safety agencies, veterinary authorities, or plant health regulators.
Exporters will need to submit enterprise information, inspection records, production site details, and compliance documentation to these authorities, who will then forward the application to the GAC for review. This government-to-government submission process mirrors the mechanism applied under GAC Decree 248 for food manufacturers and ensures that only enterprises meeting domestic and Chinese standards are recommended for registration.
3. Obtain and maintain GAC registration
Once approved, the overseas enterprise will be added to the GAC’s official registry and issued a Chinese registration number, which becomes the core identifier for customs declaration and traceability. Registration records typically include enterprise name, production address, product scope, inspection certificates, and relevant compliance data.
Under existing precedents such as GAC Decree 248, registration is valid for approximately five years, after which renewal and re-evaluation may be required. Exporters should maintain consistent inspection, recordkeeping, and communication with their competent authority to ensure continued compliance and seamless renewal.
4. Prepare pre-export documentation and labeling
To ensure smooth clearance at Chinese ports, all export documentation must clearly reference the enterprise’s Chinese registration number. This includes packing lists, health or quarantine certificates, inspection records, certificates of origin, and commercial invoices.
Labeling must meet China’s requirements for agricultural and food imports, typically including bilingual Chinese-English information, detailed product descriptions, and traceability data. Products that do not comply with labeling rules risk inspection delays, relabeling requirements, or customs rejection.
5. Fulfill importer responsibilities in China
Chinese importers play a critical role in completing the declaration process under the new system. Before importing goods, importers must verify the exporter’s registration status through the GAC’s registration database or the “Internet + Customs” platform.
When submitting import declarations, importers are required to enter the overseas enterprise’s Chinese registration number under relevant section. For declarations involving multiple product items, the correct registration number must be matched to each item individually.
Any inconsistency (such as incorrect or expired registration data) may result in quarantine holds, extended inspections, or denial of entry, placing financial and logistical burdens on both exporter and importer.
Conclusion
China’s new declaration and registration requirements for overseas agricultural enterprises highlight the growing importance of transparency, traceability, and regulatory alignment in entering the Chinese market. While the updated system introduces clearer expectations for exporters and importers alike, it also reinforces the need for structured compliance planning, beginning with understanding product classifications, completing required registrations, and ensuring accurate documentation throughout the supply chain.
For businesses seeking to sell agricultural products to China, multiple market entry pathways remain available. Traditional import channels continue to suit bulk commodities and long-standing B2B partnerships, while cross-border e-commerce provides a fast-growing route for higher-value, packaged agricultural goods. Free Trade Zones (FTZs) and pilot programs offer controlled environments to test demand, and more established exporters may benefit from deeper collaboration with Chinese partners through joint ventures or exclusive distribution agreements.
Ultimately, the regulatory changes do not mean to close the door to foreign suppliers; rather, they are designed to clarify the rules of engagement. Exporters that adapt early, coordinate closely with local partners and competent authorities, and use the appropriate market-entry channel will be well positioned to capture opportunities in China’s large and evolving agricultural market.
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