The General Administration of Customs (GAC) in China has recently unveiled a draft amendment aimed at refining the registration process for overseas food manufacturers exporting to China. This proposal, open for public comments until February 19, 2025, introduces significant changes intended to enhance efficiency and address practical challenges faced by foreign producers.

A key highlight of the draft is the introduction of a system recognition pathway for overseas facility registration. Under this new mechanism, competent authorities from recognized countries or regions can obtain approval from GAC. Once approved, these authorities can submit a list of recommended manufacturers to GAC, which will then register these enterprises and assign official registration numbers. This shift potentially simplifies the registration process for manufacturers from recognized countries, as they may no longer need to submit individual applications directly to GAC. Instead, coordination with their home country's competent authority becomes crucial to ensure inclusion in the submitted list.

The proposed amendments also introduce flexibility in dossier requirements for manufacturers whose home authorities are not recognized by GAC. These enterprises must apply for registration either directly or through an agent, with dossier requirements varying based on the type of food product. Notably, the draft updates the Catalogue of Foods that Require Official Recommendation Registration Letters, listing 11 categories of high-risk foods subject to government-recommended registration. Eight types of food, including health foods and certain raw materials, may no longer require the current recommended registration process, streamlining market entry and reducing compliance costs for these manufacturers. The dynamic adjustment of the Catalogue allows for rapid adaptation to changes in the food industry and regulatory landscape.

Additionally, the draft removes the requirement for overseas manufacturers to reapply for registration under certain scenarios, such as changes in legal representation or registration numbers. Reapplication will only be necessary if changes significantly impact sanitation management and food safety controls, such as relocating production sites. Furthermore, the draft clarifies exemptions from facility registration for specific food categories, including items sent via mail or express delivery, cross-border e-commerce retail products, and traveler-carried goods. It also maintains the exclusion of food additive manufacturers from the facility registration requirement.

The proposed changes reflect China's commitment to enhancing food safety oversight while simplifying administrative procedures for overseas manufacturers. However, some ambiguities remain regarding how the new system recognition mechanism integrates with existing regulations. For instance, it is unclear whether already registered companies need to coordinate with their competent authorities to be included in future lists provided to GAC. Addressing these uncertainties will be vital for ensuring a smooth transition and supporting businesses as they navigate the evolving regulatory environment.