Imported foodThe "ID Card": Why is it mandatory to register overseas production enterprises?

Recently, a long-time client who imports Australian infant formula complained to me: "Manager Zhang, we just had a shipment detained at the port because the manufacturer wasn't on the customs registration list..." I handle over a dozen such cases every year. Today, let’s thoroughly discuss the "clearance code" for imported food—the registration of overseas manufacturers.

According toArticle 96 of the Food Safety LawAll overseas food manufacturers exporting to China must be registered with the General Administration of Customs. Just like needing a passport to travel abroad, without this "ID," even the highest-quality imported food cannot enter the country.

• Legal red line: Products from unregistered manufacturers face fines of 10%-50% of the goods value upon entry
• Clearance requirement: The registration number must be truthfully labeled on the outer packaging
• Dynamic management: Valid for 4 years, renewal must be processed 1 year in advance

Pitfall avoidance guide for registration applications: Three essential conditions

Last month while assisting a New Zealand honey company with registration guidance, I found many manufacturers get stuck on basic requirements. The General Administration of Customs clearly states that applicants must simultaneously meet:

1. Passed national system evaluationThe veterinary services and plant protection systems of the country of origin must pass evaluation by China Customs
2. Raw material safety certificationAnimal and plant raw materials must originate from disease-free zones, with high-risk products requiring risk control certification
3. Official regulatory complianceEnterprises must be approved by the competent authorities of their country and continuously comply with Chinese sanitary standards

Special reminder: Last year, a Thai durian processing plant delayed its entire registration process for six months due to inability to provide disease-free zone certification for its orchards. We recommend enterprises conductCompliance self-inspection.

Practical experience: 6 key points in preparing registration documents

Through processing 200+ registration cases over these years, Ive summarized the golden rules for document preparation:

• Bilingual versionsAll documents must be in Chinese or English, with other languages requiring officially certified translations
• Official Endorsement: Must be submitted through the competent authority of the country of origin; applications filed by enterprises directly will be invalid
• Complete Process: Flowcharts must indicate critical control points. We have encountered cases where applications were rejected due to missing sterilization process descriptions
• Floor Plan Standards: Workshop layout diagrams must clearly mark functional zone divisions and material flow directions
• Declaration Documents: The conformity declaration from the competent authority must bear official signatures and seals
• Epidemic Reports: Must include animal and plant epidemic monitoring data from the most recent 3 years

Detailed registration process: From application to public notice in 20 working days

The General Administration of Customs commits to completing approvals within 20 working days (excluding expert review time). In actual operations, we found these time nodes crucial:

Last year when assisting a French cheese factory with registration, we prepared a list of common review questions in advance and completed the registration 7 days ahead of schedule

Ongoing compliance: 5 major management points after registration

Obtaining the registration number is just the beginning. We recommend enterprises establishfour-in-onecontinuous compliance mechanism:

• Change management: Enterprise name and address changes must be reported within 30 days
• Annual self-inspection: Conduct compliance checks against Chinese standards
• quality traceability: Retain production inspection records for at least 2 years
• Crisis contingency plan: Establish a rapid response mechanism for food safety incidents
• Label management: Ensure each batch of goods is correctly marked with the registration number

Remember, the General Administration of Customs conductsregistration reviewat irregular intervals. Last year, 3 companies had their registration qualifications suspended due to failure to meet production standards.

Special reminder: These situations may lead to registration cancellation

According toGeneral Administration of Customs Order No. 243, registration will face revocation under the following circumstances:

1. Causing major food safety incidents
2. Multiple non-compliances detected within one year
3. Leasing or lending registration numbers
4. Provision of false materials
5. Still failing to meet requirements after rectification

Last year, a Southeast Asian aquatic product company was permanently disqualified for transferring registration numbers, leading to intensified inspections for over ten companies in the same industry in that country.

Finally, heres an industry insight to share with everyone:"Registration compliance is the foundation, and ongoing management is the key."For any questions regarding imported food registration, feel free to discuss anytime!