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China food import rules: what applies now?
GACC Decree 280 replaced Decree 248 on June 1, 2026. It governs registration of overseas food manufacturers. It did not repeal Decree 249, the separate import and export food-safety framework. Exporters need to resolve market access, establishment registration, product compliance and shipment clearance as separate tasks. Decree 280, including its repeal provision in Article 33.
This guide covers commercial food exports to mainland China. Research checked September 9, 2026 against government publications. Product category, origin and trade channel determine the exact requirements; use the checklist below with your importer and home-country competent authority before producing a shipment.
The requirements at a glance
| Check | Question to resolve | Evidence to keep |
|---|---|---|
| Market access | Is this product from this country eligible, including any protocol or suspension? | Current country/product access conditions and certificates required by the competent authority. |
| Manufacturer registration | Is CIFER the applicable route, and is official recommendation required? | Approved establishment, product scope, registration number and validity. |
| Importer and exporter responsibilities | Who handles filing, supplier verification, declarations and traceability? | Named importer, broker and compliance contacts, with responsibilities agreed in writing. |
| Product and label compliance | Do ingredients, additives, claims, packaging and labels meet the applicable Chinese requirements? | Approved product specification, artwork and category-specific testing or approval records. |
| Customs release | Do shipment documents and declared details match the approved product and manufacturer? | Consignment documents, certificates, declarations and release records. |
Who oversees food imports?
GACC handles imported-food controls, including overseas establishment registration and border procedures. Food safety standards and domestic market requirements also involve the National Health Commission and the State Administration for Market Regulation. Start with GACC’s imported-food service guidance for the customs process; obtain product-specific requirements rather than relying on a generic certificate list.
Decree 280, former Decree 248 and Decree 249
Under Decree 280, overseas producers, processors and covered storage facilities must obtain the applicable GACC registration. Food additives and food-related products are outside this decree’s manufacturer-registration scope. That exclusion does not exempt those products from their own import and safety rules. Registrations last five years, with renewal and change-management conditions. The officially hosted English reference text explains these boundaries; use the Chinese legal text when resolving an interpretation.
Existing registrations do not become invalid merely because Decree 280 took effect. Australia’s June 2026 implementation notice confirms that existing registrations remain valid and that the new rules apply to new applications, amendments and renewals from June 1. It also cautions that some implementation details require further guidance. DAFF implementation notice.
GACC registration: choose the correct route
Step 1: Classify the actual product and establishment
Prepare the product’s ingredients, processing method, intended use, origin and proposed HS classification. Identify the actual production site, any relevant processor and cold storage, rather than assuming the brand owner’s name is sufficient. Ask the importer and competent authority to confirm the applicable category before opening an application.
Primary edible agricultural products can follow a separate quarantine-registration route. Canada’s notice identifies examples including fresh vegetables, dried beans and unroasted coffee or cocoa beans. Removal from CIFER does not mean removal from registration: the relevant GACC animal-and-plant quarantine requirements must still be checked. Cross-border e-commerce also has its own applicable rules; do not assume it creates a general exemption. CFIA explanation of agricultural products and e-commerce.
Step 2: Check the official-recommendation catalogue
The former fixed 18-category list has been replaced by a dynamic catalogue. The implementation catalogue contains 17 categories requiring competent-authority recommendation. Singapore’s current notice lists:
- Meat and meat products; casings; bird’s nests and their products.
- Bee products; eggs and egg products; dairy products; aquatic products.
- Edible fats and oils; stuffed wheaten foods; edible grains; grain flour and malt.
- Dehydrated vegetables; seasoning powder; nuts and seeds; dried fruits.
- Special dietary foods; health foods/dietary supplements.
For a catalogue product, coordinate the required official recommendation with the competent authority in the production country. Do not interpret the ability to submit electronically as permission to bypass that recommendation. Singapore Food Agency’s Decree 280 circular.
Step 3: Apply through the official CIFER system
The official address is cifer.singlewindow.cn. Use its product-category inquiry and service guides to confirm classification and application materials. Applications, changes and other registration business can be managed there, and applicants can review progress and GACC feedback. GACC does not charge a registration or filing fee; any consultant’s charge is a separate private service. GACC implementation announcement.
For foods outside the official-recommendation catalogue, the manufacturer or its authorized agent can apply through the applicable registration route. Decree 280, Article 9.
Build a controlled application folder: legal establishment name and address, registration details in the home country, product scope, process information, food-safety documentation and the relevant declarations. Assign one person to reconcile Chinese and original-language entries. Do not buy packaging based on an application number or an intermediary’s promise of approval.
Step 4: Verify the approval before shipping
Check the approved establishment and products against the actual goods. Record the registration number and validity in the shipment file. Confirm that the manufacturer’s details on health certificates and shipping records agree with the approved listing. Australia’s China dairy export guidance warns that inconsistent establishment details can lead to detained consignments.
Step 5: Maintain registration and manage changes
Eligible registrations can renew automatically for another five years. Meat and meat products, plus bird’s nests and their products, are excluded from automatic renewal; the manual application window is three to twelve months before expiry. Regulatory action can also prevent automatic renewal. Changes that materially affect food-safety or hygiene management may require a new application, while other changes still require a modification request. DAFF summary of Articles 20–22.
Keep an expiry calendar even when automatic renewal is expected. Recheck the status after a factory move, ownership or legal-representative change, new product category or regulatory incident. A previously valid number is not proof that a different site or product is covered.
Chinese labels, packaging and the 2027 transition
Review the label against the actual product category
For prepackaged retail food, commission a Chinese-language label review covering the food name, ingredients, nutrition information, net contents, dates, storage instructions, origin and responsible-party details as applicable. Verify claims and additives against the product’s Chinese classification. A translation of a home-market label alone is not a compliance review.
Decree 280 Article 14 requires the Chinese registration number or the registration number approved by the home-country competent authority to be shown on food packaging. This general rule does not replace additional category-specific packaging instructions. Decree 280.
GB 7718-2025 takes effect on March 16, 2027
The new general prepackaged-food labeling standard has been published, but its effective date is March 16, 2027. Do not describe it as already mandatory in September 2026. Australia’s notice explains that GB 7718-2025 will replace GB 7718-2011 and should be read with SAMR’s food-labeling measures. Use the transition period to review artwork and packaging inventory against the rules applicable to your production and shipment dates. DAFF labeling transition notice.
The NHC publication also includes GB 28050-2025 for nutrition labeling. Obtain the full applicable standards and category rules for the label review, especially for infant foods, special medical-purpose foods and claims. NHC standards announcement.
Customs clearance: prepare the shipment before dispatch
Match the documents to the goods
Ask the importer and broker for a product-specific document matrix. It should identify who supplies each document, when it must be issued, and which entries must match. Common commercial records include the invoice, packing list and transport document; official health, quarantine, origin or product-approval documents depend on the goods and access conditions. GACC’s guidance specifically flags approvals for certain categories before declaration. GACC import process.
Registration information belongs in the customs declaration
The implementation announcement specifies the overseas manufacturer registration number under license category code 519 in the relevant product-qualification field, with the stated human-consumption purpose. It also distinguishes the registration-validity conditions for officially recommended and independently registered manufacturers. Have the broker verify those conditions for the production and declaration dates; do not assume an expired registration can always be used. Declaration requirements in the implementation announcement.
Plan for inspection and traceability
Agree in advance who will respond to a customs query, provide originals, arrange sampling and manage storage if release is delayed. Keep batch, production, shipment and customer records connected so the importer can trace affected goods. Do not promise a universal clearance timeline: the product, access rules, documents and controls determine what happens at the border.
Product-specific checks that change the route
| Product | Additional check |
|---|---|
| Meat, poultry and seafood | Country access, approved establishments, health/quarantine certification, cold chain and any active restrictions. |
| Dairy | Approved product scope and establishment details; distinguish ordinary dairy from infant formula or special-use products. |
| Health foods and special dietary foods | Product classification and any product/formula registration or filing, separately from establishment registration. |
| Beverages and formulated foods | Ingredient and additive permissions, category standards, claims and the specific labeling requirements. |
| Primary agricultural products | Separate quarantine-registration route and origin/product eligibility. |
Cold storage is another classification question. Canada’s guidance distinguishes covered cold storage of terrestrial and aquatic animal-based foods from storage of other products at ambient temperature. Confirm the facility’s actual role and goods with the competent authority; do not infer that every warehouse must register in CIFER. CFIA storage clarification.
Tariffs and landed cost
Have the customs broker confirm the HS classification, customs value, origin and applicable duty, VAT and any other taxes or trade measures at the planned entry date. Preferential treatment depends on the relevant agreement and proof of origin. There is no single “China food tariff” that can be safely applied to every product.
Build a commercial model that includes testing, artwork changes, certification, freight, customs handling, cold storage where needed, and the cost of a delay. Set responsibility for those costs in the importer or distributor agreement before committing inventory.
Pre-shipment checklist for the exporter and importer
- Access: Confirm the exact product/origin combination is eligible and record the current source.
- Registration: Confirm the route, manufacturer, covered products, status and number.
- Product: Sign off ingredients, specifications, required approvals and testing.
- Artwork: Approve Chinese labels, registration marking and the relevant transition dates.
- Documents: Cross-check manufacturer identity, product description, quantity, batches, dates and certificates.
- Declaration: Have the broker validate registration and classification entries.
- Exceptions: Name the person who can resolve an inspection query and decide on delayed, returned or noncompliant goods.
A useful handover is a single shipment file with a named owner for each open issue. Do not load the shipment while an unresolved issue affects eligibility or mandatory documentation. After release, retain the records and reconcile the first shipment’s actual costs before expanding.
Frequently asked questions
Does Decree 248 still apply?
Decree 280 repealed it from June 1, 2026. Older guides can still explain historical processes, but current registration decisions must use Decree 280 and the applicable implementation guidance. Existing registrations were not automatically cancelled by the transition.
Does GACC registration guarantee customs clearance?
No. Registration is one requirement. The product must also meet market-access, safety, labeling and consignment requirements. Treat approval of a facility separately from approval of every product it could manufacture.
What should we do if customs rejects a shipment?
Obtain the written reason through the importer or broker and identify the affected batches. Ask the responsible authority which corrective action is permitted for that failure before changing labels or reshipping. Record the decision, costs and corrective action; do not assume every rejection can be fixed at the port.
How can exporters keep the requirements current?
Check CIFER and GACC notices alongside the exporting country’s competent-authority guidance. Recheck when the product, factory, supplier, label or trade channel changes, and before shipping. A consultant can support the work but cannot replace an official approval. When these rules need to be applied to a live SKU, GourmetPro’s label and regulatory compliance review checks the label and formulation against the target regime and sets out each countermeasure.
Connect compliance with the route to market
Once eligibility is clear, use our China distributor selection guide to define importer responsibilities and partner requirements. The China go-to-market guide connects channel choices with commercial planning. For support coordinating market entry, explore GourmetPro in China or distributor and partner search.
