Mandatory GACC registration for all F&B exporters from 1 January 2022
On 8 December 2021, the EU SME Centre and its leading consortium partner, the China-Italy Chamber of Commerce, held their webinar on new major regulations from the General Administration of Customs of China, which require all overseas F&B manufacturers exporting to China to have a new registration code printed on the labels of all their F&B products to clear customs since 1 January 2022. The webinar was hosted by Mr. Alessio Petino who invited key China experts Lina Bartuseviciute from LITAO Consultancy Group, Raymond NG with Lavinia Yao from Accestra Consulting, and one China Customs Officer, to discuss what will change for SMEs exporting to China.
Lina was nominated to start the discussion by sharing opportunities new regulations bring to EU F&B brands and set the stage for regulatory compliance consultants and China Customs Officer who was the main creator of these regulations. She also explained the context why regulations will come to an effect as soon as next month. There is an urgency for businesses to comply with F&B safety standards following recent media coverage on how COVID break-outs in China were attributed to imported foods and more local counterfeit goods promote false country of origin deceiving the public.
During the event, the regulatory experts from Accestra Consulting clarified the requirements and showed step-by-step guidance for self-registration on GAC’s platform. The speakers together with China Customs Agent addressed questions raised by over 100 participants, including, F&B producers, exporters, business organizations and government bodies such as ministries and embassies from Europe and neighbouring countries. This episode will be particularly useful to understand what will change for SMEs and how to register on the GAC platform for free before the deadline of 1 January 2022.
- What is GACC registration and what happens after 1 January 2022?
Overseas F&B product manufacturers are required to register with GACC (General Administration of Customs China) in order to be able to export their products to China.
After 1 January 2022, the Chinese importer will have to provide the GACC registration number to the customs officers in order to receive the goods. The products made by manufacturers that have not received the mandatory GACC registration number will not be able to clear China customs after 1 January 2022.
More information in English available here and you can click here to download a brief overview presented by Raymond NG of Accestra (first download file in the page).
- Can I register on the database after 1 January 2022?
The database will be open any time for enterprises to register and they can register when the need arises after 1 January 2022.
- For registration of products within 18 high risk categories, who is the ‘competent authority’ in my country that I should approach for help?
The manufacturers who produce within 18 high risk categories should be applying for GACC registration number through recommendation by local authorities.
The assigned competent authority will depend on the country, but it will be working in alignment with your national ministry of agriculture and you can seek help with your case locally there or by reaching out to EU SME Centre.
- What happens if my products are already in China, but I don’t have a GACC registration number yet? What happens if my products are already in a bonded warehouse in China, but I haven’t cleared customs yet?
The products that show the manufacturing date prior to 1 January 2022 will be allowed to clear customs and sold in China without adjusted labeling, provided that the manufacturer has acquired the GACC registration number. If the products are manufactured after 1 January 2022, the labeling has to follow the new regulations, as stipulated by GACC Decree 248, Article 15:
“Regulations of the People’s Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food (Decree 248)”. Article 15:
The registered manufacturer shall mark the Chinese registration number or the registration number approved by the competent authority of the exporting country/region on the inner and outer packaging of the foods exported to China.
© Accestra. Raymond Ng “4 Ws of GACC Registration”
- Our company does not have a regular supplier of raw materials, we change them constantly depending on various factors. How do I fill the relevant information in the system?
It is recommended to fill the information on all your known suppliers of raw materials, i.e. those that you will potentially use in the future, regardless of whether you are using them at the moment or not. It doesn’t matter if in the end you will not use any of the suppliers listed in the registration.
- Our company purchases raw materials from a broker, not from the direct producer. How do I fill the relevant information in the system?
If possible, it is recommended to obtain the relevant information on the raw material producer from your broker. If not possible, then you can fill the relevant information on your broker. In fact, as a rule of thumb, you should fill the information on the supplier with whom you have the most direct relationship.
- What happens if I am selling my F&B products through China’s Cross-Border E-commerce? For example on Tmall Global, JD Worldwide, KAOLA and etc?
The mandatory GACC registration from 1 January 2022 is required for products entering China through general trade and is currently not required for products sold via cross-border e-commerce channel.
- How can I register if I am exporting the products, but I am not the manufacturer?
The GACC regulation starting on 1 January 2022 and the single window registration system https://cifrt.singlewindow.cn is set up specifically for registration of foreign F&B manufacturers whose products will be exported to China. If the exporter is only responsible for exportation of goods and they do not manufacture or process the goods, they should only submit an export filing on a separate system: http://ire.customs.gov.cn/#.
- How can I register through self-registration?
We have presented the step-by-step process during the webinar, currently accessible here: https://www.youtube.com/watch?v=ks5BSKuArKQ. And you can also click here to download an informative guideline prepared by Lavinia of Accestra (second download file in the page). Or go to GACC’s website to download the official user manual in Chinese – no translation in English is available at the moment.
- If I have more than one production facilities, how should I do the GACC registration?
If you have different production sites, your registration should be filed for each site.
- If I have my product partially made in one country at one location, and my finished product is exported from another location, which enterprise should I register in the manufacturer’s registry database?
There is no clearly defined regulation, but the rule of thumb would be that the company that completes the finished product and the country where the production process is completed will be regarded as the ‘country of origin’, and this is the manufacturer that will need to be registered in the single window system. We will be happy to consult on individual cases to find the best solution for your GACC registration.
- What are the labelling requirements for GACC registration number? Where do I need to display the GACC registration number?
Currently there is no clearly defined placement or template of how the GACC number should be indicated on the packaging and where.
It is mandatory to have a Chinese label on each product imported to China, and you can include the registration number on the label or add another sticker onto your product indicating registration number after 1 January 2022.
- How long does it take for GACC to provide me with the registration number after I submit the application?
It depends on how thoroughly the applicant has prepared and filled in the information. If you need to edit or clarify the information uploaded, the process might extend until you upload the information correctly and clarify emerging questions.
Accestra has been successful in completing the registration within 7/8 days for manufacturers of low-risk food categories, while the timeline varies significantly for the high-risk categories and depends on the national competent authority’s involvement.
- How can I know what is my application status?
Once the information is uploaded, the system will issue your unique log in registration code [在华注册资格编号] that you can use to access your application status. The official user manual uploaded by GACC on 1 December 2021 indicates the following there are 16 application statuses and you will be notified by the system once there is a development in your filing:
| Status | Explanation |
| Saved | The information has been saved. |
| Submitted (to Competent Authority) | The application has been submitted to overseas competent authority. Awaiting review. |
| Submitted (to GACC) | 1. Overseas competent authority has recommended your application to GACC to approve.
2. Manufacturers need to submit the application to GACC. |
| Recommendation not accepted | GACC or overseas competent authority rejected the application. |
| Status | Explanation |
| Successful delivery to GACC | The application has been submitted to GACC successfully through the system. |
| Failed delivery to GACC | Due to network or connection problems, the application failed to reach the GACC through the system. |
| GACC received the application | GACC received the data successfully in the system. |
| GACC did not receive the application | GACC failed to receive the data in the system. |
| Accepted | GACC accepted the application and will start the review. |
| Not accepted | GACC did not receive the application and did not start the review. The application is returned to the applicant. |
| Please upload supplementary documents | 1. The application did not meet related requirements. The manufacturer or overseas competent authority need to revise the application.
2. Overseas competent authority rejects manufacturers’ applications. Manufacturers should revise the application. |
| Fail the review | GACC rejects the application from manufacturers or the recommendation from overseas competent authority. |
| Pass the review | Overseas food manufacturers meet the requirements. GACC approves the registration and grants registration number. |
| Withdrew | GACC withdrew the registration number for manufacturers. |
| Suspended | GACC suspended the food importation until the manufacturer rectifies non-compliant items. |
| Needs revisions | For manufacturers that have already obtained the registration number but failed to meet the registration requirements, GACC requires manufacturers to revise and update the non-compliant items. The importation will be suspended until the manufacturers are compliant with the requirements. Manufacturers should update identified items within a specified period, submit a written report and declaration. |
- Business identity documents submitted in other EU languages, not English or Chinese
According to Article 9 of GACC Order 248, business identity documents must be submitted during the registration, such as the commercial license granted by the competent authorities of the country itself, issued in Chinese or English. In Europe, however, many countries issue such documents only in their language, not in English.
In this case, you must see if there is an agreement between China and your country for Food Entry, Inspection and Quarantine, then you have to follow the provisions in it in terms of language. If the Agreement says that documents can be submitted in other languages, then it is possible for you to submit in other languages. If the Agreement doesn’t have such provisions, or if there is no Agreement at all, then you must submit the information on GACC’s system in English or Chinese. If not possible to have business identity documents issued directly in these languages, you must have notarised translations into English or Chinese.
- How to add new products after a GACC registration code has been obtained
Currently, after a registration code has been obtained, GACC’s system does not allow to add new products to the same registration. The option ‘add’ is blocked, as shown below:
We have verified with the Chinese Customs, which said that this is a temporary IT issue which is currently being addressed, and is expected to be solved soon although a specific date was not given. In the meantime, there are only two options available:
- Submit a completely new registration, listing all the products within the same category.
- Wait until the system is fixed.
More information
For more Q&As, please watch the original interview with the GACC officer here on EU SME’s YouTube channel. If you have any questions or would like to know in more detail certain aspects of the GACC registration, please feel free to reach us by email or through our ‘ask-the-expert’ function on our website: https://www.eusmecentre.org.cn/expert.
The user manual was uploaded on the official GACC website on 1 December 2021 and is available here in Chinese: http://www.singlewindow.cn/xzlm/5768.jhtml
About EU SME Centre
The EU SME Centre is a European Union initiative that provides a comprehensive range of hands-on support services to European small and medium-sized enterprises (SMEs), getting them ready to do business in China. Experts in the Centre provide advice and support in four areas – business development, law, standards and conformity and human resources. Collaborating with external experts worldwide, the Centre converts valuable knowledge and experience into practical business tools and services easily accessible online.
The EU SME Centre is now managed by five implementing partners who guide the strategic development and management of the Centre through their knowledge and experience of the China market– China-Britain Business Council, China-Italy Chamber of Commerce in China, Danish Chamber of Commerce in China, EUROCHAMBRES and European Union Chamber of Commerce in China.
https://www.eusmecentre.org.cn/
About the China Customs Officer
The Customs Officer is the Director of TBT Research Centre of International Research Center for Inspection and Quarantine Standards and Technical Regulation of GACC and the main drafter of Orders 248 and 249 of the General Administration of Customs.
He has been engaged in the research of food, chemical technical trade measures, risk analysis and risk warning. He has been awarded with the second and third prizes of the scientific and technological inspections at the ministerial for the research projects he participated in. Additionally, he edited and participated in a dozen of related books. He has played a positive role in removing foreign technical trade barriers, establishing China’s technical preventive measure system, and promoting the development of foreign economic trade.
About Lina Bartuseviciute
Ms. Lina Bartuseviciute has been in Shanghai for almost 12 years. Due to her cultural know-how and language proficiency, as well as International Relations Master’s Degree in Fudan, she has been included in multiple high stakes governmental meetings and negotiations, hosted numerous delegations and bilateral talks. Since 2015, she has founded LITAO www.litaogroup.com – a business consulting firm focusing on China Market Entry, which works to bring quality European F&B brands to China market, with support from European Union.
About Raymond NG
Mr. Raymond Ng is the Regulatory Affairs Consultant at Accestra Consulting. He has a Master’s degree from University of Nottingham and has extensive knowledge on Chinese Food & Beverage, Cosmetics and Pharmaceutical import & export regulations. His research specialises in China’s national standards and the impact it has on international businesses. He has vast insight and practical experience in dealing with Chinese market access requirements and accumulated a successful track record with supporting international exporters with market entry in to China.
About Lavinia Yao
Ms. Lavinia Yao is the Senior Regulatory Consultant at Accestra Consulting. She has a Master’s degree from Zhejiang University in Food Science and Engineering. Ms. Yao has years of experience in the food industry and is an expert in China food laws, regulations and national standards. Her daily work involves solving practical food regulatory problems for global food businesses, covering regulatory compliance in food labelling, food additives registration, health foods, food contact materials related regulations and others. She is often invited as a keynote speaker to numerous high-level conferences organized by the government; an indispensable asset in her line of work for responding to international client’s needs.
