China registration rules: Foreign food companies must now pass ‘expert panel’ reviews
These updated rules are under the purview of the Department of Animals and Plants of the General Administration of Customs (GAC) of China, and apply to all companies dealing with the production, processing and storage of animals, plants and the related products who wish to apply for the registration of these in the country.
In the updated regulatory document as published by GAC on November 29, after an application is received from any foreign company that fits the above criteria, an initial documentation review will take place before the application is accepted.
After acceptance, the department will then take steps to form an expert panel to review the application.
“The Department of Animals and Plants will, depending on the application requirements, select experts from the various local customs by considering their related professional backgrounds and experience,” said the GAC.
“These experts will form both a document review expert panel and an on-site review expert panel.”
Expert document reviewing will take place first to endure adherence to both protocols and Chinese regulations, following this group will form the on-site review plan to be conducted by the on-site review expert panel.
“A very important point [that applicant food companies need to take note of to pass these reviews] are to adhere to the Department of Animals and Plants’ requirements as has been made available on the official website,” GAC added.
“It is also crucial that the application form and all related materials [have been scrutinised so as to make sure that these] are both complete and also meet all required specifications.”
The applicant company’s safety and hygiene conditions as well as its quality control system will also need to be verified from several aspects, including the formal business registration and management system in its country-of-origin, compliance with Chinese regulations and standards, and adherence to recommended work procedures equal to that of companies registered in China.
Similar operational procedures and requirements will be observed for overseas food companies wishing to make extensions or alterations to existing registrations.
How this will affect different types of food companies
Even though the basic requirements for most types of foreign food firms are mostly similar (e.g. completed application forms, professional certificates, pictures of key areas in the facility), some extra items are required for those that deal in specific sectors.
One example here is for grain-related companies, which are required to submit detailed explanations of all operational and management systems, quality control procedures, and raw material traceability management, in addition to pest control measures.
This could be related to China’s move earlier in January this year to tighten regulations on grain circulation and strategic reserves, with the aim of raising national grain security.
Companies that deal with fruit packaging for export are also required to provide full details on the facility’s setup, packaging process flow as well as a list of orchards from which the fruits are sourced, most likely to allay concerns about preservative and pesticide use.
“These firms will also need to provide a copy of the relevant fruit production and purchase contracts and details,” said GAC.
Full details are available at the GAC website here (Word document in Mandarin).