Good News for GACC Registration! Health Foods and Special Dietary Foods May No Longer Require Official Recommendation for Registration

On January 3, 2025, the General Administration of Customs of the People’s Republic of China (GACC) issued the Draft Regulations on the Administration of Registration for Overseas Food Production Enterprises Importing into China to solicit public opinions. The deadline for feedback is February 19, 2025.

CIRS has compared the draft with the current regulations (referred to as “Order No. 248”) and summarized the key changes as follows:

Introduce system recognition to optimize registration procedures

The draft introduces system recognition. If the food safety management system of a country (or region) is recognized by the GACC, its competent authority can submit a list of food production enterprises recommended for registration in China. GACC will grant batch registrations to enterprises on the officially recommended list and assign them registration numbers for operations in China.

Updates recommended registration categories to reduce food types

The draft reduces the food categories requiring official recommendation, from 18 to 11. This change suggests that in the future, health foods and special dietary foods may be registered independently by enterprises. This will significantly shorten the registration process and lower the difficulty for such products to enter the Chinese market, which is a major benefit for both consumers and the overall market environment.

Table 1. Comparison of food categories requiring official recommendation for registration

Note: Food categories that have changed are marked in red.

The Directory of Foods Requiring Official Recommendation for Registration is published by the GACC. If risk analysis or evidence indicates changes in the risk level of specific food categories, GACC may dynamically adjust the directory.

Exemption from registration for cross-border e-commerce and other scenarios

The draft explicitly exempts overseas food production enterprises from registration in the following scenarios:

- Foods sent via mail, courier, or cross-border e-commerce retail.

- Foods carried by travelers.

- Samples, gifts, promotional items, exhibition products, and aid supplies.

- Foods sold in duty-free shops.

- Foods intended for use by foreign embassies or consulates in China.

Insights from CIRS Group

The revisions in the draft reflect the GACC’s efforts to optimize and improve current regulations amidst the expansion of import trade. These changes provide more convenient registration conditions and a more reasonable management approach for imported foods. For health foods, allowing enterprises to self-register would not only reduce the registration timeline and difficulty but also boost confidence among importers. This is likely to encourage overseas enterprises to actively apply for the importation of health foods into China.

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