On October 14, 2025, the General Administration of China Customs issued the Regulations of the Customs of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food (Order No. 280 of the GACC) (hereinafter referred to as "Order No. 280"), which will come into effect on June 1, 2026, and the Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food (Order No. 248 of the GACC) announced on April 12, 2021 will be simultaneously abolished. As a core institutional update for the supervision of imported food safety, Order No. 280 established a new registration management system with risk management as the core, including classification management and simplified processes. In order to facilitate enterprises better understanding of the new regulations in the industry, Antion interpreted the main changes in Order No. 280 for your reference.

PART.1 Introduced the "Catalogue" Management

Article 6 of Order No. 280 stipulates that the General Administration of China Customs shall determine the catalogue of imported foods required official recommendation for registration (hereinafter referred to as the "Catalogue") based on the analysis of factors such as the source of raw materials, production and processing technology, history data of food safety, consumer groups and consumption methods of food, combined with international practices, and publish it to the public. The new regulations cancelled the original 18 categories of officially recommended registered foods and replaced them with "Catalogue" formulated and published by the General Administration of China Customs. It is expected that traditional high-risk categories such as meat and meat products and dairy products will continue to be included in the "Catalogue", but the "Catalogue" will be dynamically adjusted based on risk assessment results. For food categories outside the "Catalogue", enterprises may prepare materials on their own or entrust agents to submit registration applications to the General Administration of China Customs in accordance with Article 9.

PART.2 Newly Added the Method of "List Registration"

In order to strengthen international cooperation and adopt a more convenient "list registration" method, Article 17 and Article 18 of Order No. 280 stipulate that for countries (regions) whose food safety management systems have been recognized by China and have signed cooperation agreements, their enterprises can submit a recommended list through the competent authorities of their respective countries. After examination, the General Administration of China Customs will register the enterprises on the list in bulk. This measure can greatly improve registration efficiency and significantly shorten the registration cycle for compliant enterprises.

PART.3 Changed the Rules for "Renewal of Registration"

Changed the rules for "renewal of registration" to further simplify the management measures for renewal of registration of enterprises. The current version has a unified registration validity period of 5 years, and enterprises need to actively submit renewal application 3 to 6 months before the expiration date. Failure to apply will result in automatic cancellation. Although this requirement can ensure regulatory continuity, it has also led to a large number of registration failures due to enterprises’ negligence. On the basis of retaining a validity period of 5 years, Order No. 280 introduces a mechanism of automatic renewal as the main and active application as the auxiliary. Most enterprises can automatically renew without actively applying, except for three situations: foods being included in the "List of Foods Not Eligible for Automatic Renewal of Registration", enterprises in the rectification period and relevant foods in the country (region) where they are located being suspended from import.

For foods included in the "List of Non-automatic Renewal", enterprises may, in accordance with Article 22, submit an application for renewal of registration to the General Administration of China Customs through the registration application and prepare materials within 3 to 12 months before the expiration of the registration validity period. The new regulations reduced the costs for compliant enterprises and significantly improved the level of trade facilitation through "automatic renewal".

PART.4 Clarified the requirements for other business formats such as "cross-border e-commerce"

Article 30 of Chapter 4 of Order No. 280 newly added provisions for "overseas storage enterprises of imported food", "overseas manufacturers of primary edible agricultural products" and "overseas manufacturers of cross-border e-commerce retail imported food" to be separately announced by the General Administration of China Customs or handled in accordance with relevant regulations, clarifying the regulatory basis for other business formats such as "cross-border e-commerce" and adapting to the development of new business formats.

PART.5 Arrangement of Transitional Period

Order No. 280 will come into effect on June 1, 2026. The Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food (Order No. 248 of the GACC) announced on April 12, 2021 will be simultaneously abolished.

PART. 6 Summary

The registration of overseas manufacturers of imported food is an important system to ensure food safety and maintain stable trade development in China. As the implementation date of June 1, 2026 approaches, enterprises should fully utilize the transition period to complete compliance adjustments and jointly promote the development of the imported food market towards a safer, more standardized and more efficient direction.

Source: Antion

Note: This article is compiled by Antion. Please indicate the source for reprint.