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New Details on China’s Overseas Food Facility Registration

  • In the spring of 2021, China published the Chinese General Administration of Customs (GAC) Decree 248 – Regulations on Registration and Administration of Overseas Manufacturers of Imported Food, to impose new registration requirements on all foreign food companies.

  • In October 2021, some foreign governments (e.g., Singapore and Malaysia) provided instructions to their local food companies on how to satisfy the overseas food facility registration requirements in China.  On October 5, 2021, the Singapore Food Agency (SFA) published a notice, which states that if the producers of certain designated food categories (e.g., edible fats and oils, functional foods, egg products, condiments) have exported the products to China since January 1, 2017, they could be entitled to GAC’s fast-track registration if they can submit their declaration to SFA by October 31, 2021.  The Malaysian food authority also posted detailed guidance to facilitate the registration in China.

  • Although the enforcement date of January 1, 2022 is approaching, no official guidelines have yet been released by GAC to detail the implementation.  An overseas food company may want to reach out to the local responsible food authority to understand whether any conversation has taken place between China and its home country as to how to comply with the Chinese food facility registration requirement.

  • Note also that GAC Decree 249 – Administrative Measures on Import and Export Food Safety, under which new requirements governing the inspection and evaluation of imported foods are imposed, will also take effect on January 1, 2022.

© 2021 Keller and Heckman LLPNational Law Review, Volume XI, Number 298
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About this Author

Keller and Heckman offers global food and drug services to its clients. Our comprehensive and extensive food and drug practice is one of the largest in the world. We promote, protect, and defend products made by the spectrum of industries regulated by the U.S. Food and Drug Administration (FDA), the European Commission and Member States authorities in the European Union (EU) and similar authorities throughout the world. The products we help get to market include foods, pharmaceuticals, medical devices, veterinary products, dietary supplements, and cosmetics. In addition...

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