Food – Accestra Consulting

All you need to know about GACC Single Window Registration for F&B Manufacturers

Accestra — Wed, 15 Dec 2021 07:24:47 +0000

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.

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.

http://english.customs.gov.cn

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.

lb@litaogroup.com

www.litaogroup.com

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.

raymond@accestra.com

https://www.accestra.com/

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.

yaolu@accestra.com

https://www.accestra.com/

Mandatory GACC registration for all F&B exporters from 1 Jan, 2022

Accestra — Fri, 26 Nov 2021 12:03:11 +0000

Date: Wednesday, 8th December, 2021
Time: 4 – 5:30 (Beijing）
Time: 9 – 10:30 AM CST (Brussels)
Price: Free of charge

Click here to register. You will then receive an invitation to this webinar. Please note that the number of participants is limited.

TOPICS and SPEAKERS:

In April 2021, China’s General Administration of Customs (GAC) issued Order 248 and Order 249. These two major regulations require all overseas F&B manufacturers exporting to China to register, before 1 January 2022, on a platform designated by GAC, and to display the registration number of the label and package. Failure to do so will prevent European F&B companies to export their products to China.

As we are approaching the deadline for registration, lot of uncertainty remains. Companies still have many doubts on the registration procedure for their F&B products, are encountering technical issues when register on GAC’s platform, or are not entirely clear on the changes to be adopted to their labels and on what constitute ‘inner package’ and ‘outer package’. The EU SME Centre is receiving several emails every week from European SMEs seeking assistance.

In order to make some clarity and to prevent any interruption of exports from EU SMEs to China, we are partnering up with two key experts from consulting firms Accestra and Litao Consulting, for a webinar on the topic. Together, we have invited a Customs Officer from GACC to give a presentation and answer questions from SMEs.

Key content to be covered include:

What, why, where and who needs to register on GAC’s platform
Procedures for registration: recommendation from national authorities and self-registration
Step-by-step guidance for self-registration on GAC’s platform
Labelling requirements
Impact of the new regulations on market dynamics EU exporters
Insights on successful factors for F&B products, B2B distributors and Chinese consumers preference
Tips and pitfalls

A Q&A session will follow, during which real cases of inquiries received by the EU SME Centre from EU SMEs.

Participation is free of charge for EU SMEs, business organisations and government institutions.

CHINA CUSTOMS OFFICER

CHINA CUSTOMS OFFICER FROM TBT RESEARCH CENTRE OF INTERNATIONAL RESEARCH CENTER FOR INSPECTION AND QUARANTINE STANDARDS AND TECHNICAL REGULATIONS OF GACC

RAYMOND NG

REGULATORY AFFAIRS CONSULTANT @ ACCESTRA

Mr. Raymond Ng 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.

LAVINIA YAO

SENIOR REGULATORY CONSULTANT @ ACCESTRA

Ms. Lavinia Yao 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.

LINA BARTUSEVICIUTE

FOUNDER & MANAGING DIRECTOR @ LITAO CONSULTING GROUP

Ms Lina Bartusevičiūtė has lived in Shanghai for 12 years. She is fully fluent in Chinese and in fact she started out as interpreter for business and negotiations. Soon she found out that language is just the first barrier in cross-cultural projects and for this reason set up LITAO Consulting, which is boutique go-to-market firm to be able to provide one-stop market entry solutions for European clients, particularly in the F&B sector. Just last year, together with a manufacturer of sauces & condiments from eastern Europe we developed 10 products tailored to Chinese consumer tastes, reaching more than 1000 shelves and 5 online retail channels.

Overseas Food Manufacturers Must Complete China GACC Registration by Deadline Jan 1st 2022

Accestra — Fri, 05 Nov 2021 05:02:33 +0000

What is the deadline for GACC self-registration?

All overseas food manufacturers and exporters to China must be registered with the General Administration of Customs of China (GACC) by deadline January 1^st,2022 to avoid risk of Customs clearance delays or trade disruptions.

Who needs to register with GACC?

The requirements are applicable to imported food manufacturers including:

Manufacturers of food
Processing enterprises of food
Storage enterprises of food

Which GACC Registration Pathway for you?

The registration pathways are based on the risk of the food category; there are two pathways for overseas food manufacturer registration:

Register via your competent authority. For high-risk food categories: the registration application should be recommended and submitted by your local competent authority of the exporting country/area to GACC; there are 18 food categories which should be recommended by competent authority to GACC.
Self-registration. For low-risk food categories: the registration application should be submitted by the manufacturers themselves or by qualified agents like Accestra for submission to China GACC.

How to Register at GACC Platform (Single Window)?

For manufacturers who need to submit registration application by themselves or by agents (Self-registration); manufacturers shall register on GACC Single Window or CIFER (China Import Food Enterprises Registration) platform (see below).

Fig. Login Interface of CIFER

If you do not have an account, you shall firstly register an account. After login or register, you will be guided to the registration page to complete relevant information. Kindly note the platform as of recent is only in Chinese, and not fully constructed. The website to the form can be found through the following link. You may register by yourself or appoint Accestra as qualified agent to support with end-to-end hassle-free submission and registration to obtain GACC registration number. Since the deadline is soon, it is suggested to start early and preparing the necessary information/data to obtain your registration number as soon as possible to avoid potential delays and trade disruption.

What labelling changes?

Foods & Beverage labels must be in Chinese, or Chinese and English and compliant to China’s labelling laws. A GACC registration number must be displayed on both the inner and outer packaging. We expect further details on labelling rules to be released soon, so keep in touch for updates.

If you require guidance or with support with GACC self-registration, please contact:

Email: info@accestra.com
Website: accestra.com

Contact Accestra Consulting Group

China Compliance & Market Access in a Digital World

fei liu — Mon, 01 Jun 2020 10:23:28 +0000

Tuesday 2 June, 1.30 – 2.30pm (NZST)

Brought to you by New Zealand Trade and Enterprise (NZTE), this webinar series has been designed to help your business navigate the shifting digital landscape in post-COVID China.

From mastering your digital strategy and optimising your social media investment, to understanding consumer behaviour and regulatory considerations/compliance, our experts will equip you with the insights and tools you need to adapt and grow your business in this recovering market.

In this session, Raymond Ng will help deepen your understanding of brand/distributor/retailer obligations in relation to product claims, advertisement claims and the so-called ‘professional consumer’ band related regulatory considerations.

Raymond’s presentation will be followed by a Q&A segment with guest Ricky Yang from K J BAS.

Raymond’s presentation will cover the product categories of food and beverage, health supplements and cosmetics and the topics covered include:

Key lessons from cases rejected by New Zealand customs

Product compliance (formula & labelling)

Advertising, marketing and product claims

Understanding ‘professional consumers’ and how to protect your business

Customs Credit Management System

CBEC Compliance & E-commerce law

Customs Import Procedures

Policy updates and trends

A case study in China labelling

Presenter:

Raymond Ng, Accestra

Q&A Panel:

Raymond Ng, Accestra

Ricky Yang, K J BAS

Moderator: Damon Paling, NZTE

For more information, please click below links for details:

https://www.chinadigital.nz/

https://nzchinacouncil.org.nz/events/nzte-china-digital-speaker-webinar-series/

China Customs Cancels Food Label Filling Requirements from 1st Oct 2019

raymond — Wed, 24 Apr 2019 08:23:59 +0000

After communicating with Beijing and Hangzhou Customs for clarification, we have summarised the key takeaways below:

Key Takeaways:

On April 22, Customs announced the cancellation of label filling for imported pre-packaged foods, meaning from 1st Oct 2019, importers and customs brokers will no longer have to submit to China customs product labelling documentation (inclu. Chinese labels) for imported prepackaged food products during importation.
Speedier market access: improvement of efficiency during customs clearance which enables less administrative paper work and speeds up market access.
The importer shall be responsible for reviewing whether the Chinese label of the imported prepackaged food meets the requirements of relevant GB standards.
Subject to random on-site inspection by customs or for laboratory testing which will require to provide compliant labelling documents including Chinese labels and other supporting materials.
If the Customs receives complaint regarding violation of Food Safety, Labelling and other relevant GB regulations, Customs shall verify and once confirmed, act according to law such as requesting for recalls, penalties etc.
Port to Port differences: After communicating with GACC, for some ports, Customs may still require importers to provide labelling documents as part of the check list for Customs Clearance, although they may not examine the labelling documents.

What next? Risks and Suggestions

Customs have been piloting this scheme for the past few years in some ports including Shanghai and others for lower risk food categories. What’s changed? This change officially applies to all ports and pre-packaged food categories in China.

Risk of random customs inspection it is strongly advised to prepare compliance documentation beforehand such as original label and translation, Chinese labels and other relevant supplementing information.
Responsibility weighed on the exporter and importer to ensure compliance from the very beginning. Discovering product or labelling in-compliance at a later stage when product is already on China market will have a significant impact with the risks of potential recall and penalties.
Laissez-faire & Reliance on Consumer Complaints. A shift from government control to let the workings of the free market do the work. Since the announcement of The Food Safety Law, the policy has increased the penalty for non-compliant food items including violations of Chinese labelling rules, this led to the rise of industry of professional complainers that can earn compensation of 10 times the purchase price. This has encouraged the market to identify non-compliant products to report to Chinese authorities.

Reference (Chinese Only): http://www.customs.gov.cn/customs/302249/302266/302269/2393416/index.html

Contact: Raymond@Accestra.com

Website: www.accestra.com