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☼ What are the 18 types of Food Overseas Producers registered in GACC?
Answer: On April 12, 2021, the GACC issued Decree No. 248 of Regulations of the People’s Republic of China on the Registration and Administration of Overseas Manufacturers of
Imported Food (hereinafter referred to as the Administrative Regulations). The new Regulations into force on January 1, 2022.
The new Administrative Regulations introduces the risk management principles of the Food Safety Law, adopts the “official recommended registration” mode for overseas manufacturers of 18 categories of foods,
and adopts the simplified “enterprise independent application” mode for overseas manufacturers of other foods other than the 18 categories, so as to further improve the efficiency of registration management.
The documents that need to be submitted under the “official recommended registration” mode are relatively complicated, while the application documents under the “enterprise independent application”
mode are much simpler.
☼ What are the 18 categories of foods that adopt the "official recommended registration" mode?
Answer: Meat and its products, casings, aquatic products, dairy products, edible bird’s nest and its products, bee products,
eggs and its products, edible fats and oils, stuffed pasta, edible grains, grain milling industrial products and malt, fresh and dehydrated vegetables, and dried beans, seasonings, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, foods for special dietary uses, health food.
☼ Why implement the "official recommended registration" mode for 18 categories of foods?
Answer: Based on the analysis of sources of food raw materials, production and processing technology, food safety historical data, consumer groups and consumption methods, combined with international practices, it is determined that overseas manufacturers of 18 categories of foods adopt the “official recommended registration” mode.
☼ What documents need to be provided when registering 18 categories of food overseas manufacturers?
Answer: The competent authority of the country (region) where it is located should review and check the manufacturer recommended registration,
and after confirming that it meets the registration requirements, recommend registration to the GACC and submit the following application documents:
- Recommendation letter from the competent authority of the country (region) where manufacturers are located;
- List of manufacturers and application of manufacturer registration;
- Manufacturer identification documents, such as business license issued by the competent authority of the country (region) where it is located;
- A statement recommended by the competent authority of the country (region) where the manufacturer meets the requirements of the regulations;
- The review report issued by the competent authority of the country (region) where the manufacturer is located for reviewing and checking the related manufacturers.
- If necessary, the GACC may request documents of the manufacturer’s food safety, hygiene and protection system, such as the floor plans of the manufacturer’s factory area,
workshop and cold warehouse, as well as process flow diagrams.
** It should be noted that, if risk analysis or evidence shows that the risk of a certain type of food has changed,
the GACC may conduct registration methods and application documents for the corresponding food overseas manufacturers;
if the registration methods and application documents are otherwise agreed between the related countries (regions) and China, it should be implemented in accordance with the agreement of both parties.
☼ What are the evaluation procedures of registration management for overseas manufacturers of imported food?
- The GACC, by itself or by entrusting related agencies to organize an evaluation team,
conducts evaluation and review of overseas manufacturers of imported food applying for registration through written check, video check, on-site check and combinations thereof.
- The GACC should, based on the evaluation and review, register the overseas manufacturer of imported food that meet requirements and give Chinese registration number,
and notify the competent authority of the country (region) where it is located or the overseas manufacturer of imported food in writing; for those that do not meet requirements, they should not be registered, and the competent authority of the country (region) where they are located or the overseas manufacturers of imported food should be notified in writing.
The new “Administrative Regulations” supplemented a variety of evaluation and review forms such as written check, video check, and on-site check, and the review forms are more diverse and flexible.
☼ How long is the validity period of registration of overseas manufacturer of imported food?
Answer: According to Article 16 of the new “Administrative Regulations”, the validity period of registration of overseas manufacturer of imported food is 5 years.
☼ If an overseas manufacturer of imported food needs to renew its registration, what should be done?
Answer: An application for registration renewal should be submitted to the GACC through the registration
application channel within 3 to 6 months before the expiration of the registration validity period.
The application documents for registration renewal include:
The new “Administrative Regulations” relaxed the time for initiating registration renewal,
from the previous need to initiate a renewal application one year before the expiration of the registration validity period to 3 to 6 months before the expiration of the validity period.
☼ Where can I find the approved list of manufacturer registration numbers?
Answer: The list of registered manufacturers can be queried on the website of the GACC at customs online
☼ I have completed the AQSIQ exporter registration number, do I still need to apply for the GACC exporter registration number?
Answer: AQSIQ and GACC share the exporter registration number in the database, you do not need to apply for the GACC exporter registration number again.
☼ Has the AQSIQ organization been merged with China Customs?
Answer: Note: AQSIQ form an independent electronic pass system with China Customs and CIQ, responsible for all import and export declarations and inspections. Start running new institutions and electronic systems (Single Window E-systems) on January 1, 2022.
☼ If I can find our company's GACC registration number, does that mean I don't need to register again?
Answer: In most cases, you still need to register again
- If this GACC registration number is not registered by yourself recently , you need to re-register in the new GACC system;
- If this GACC registration number was registered by yourself in the AQSIQ system before, but the GACC user ID and password can log in to the new
GACC system, then you need to re-register in the new GACC system;
- If your product belongs to the 18 risky food categories specified by GACC 248 Decree,
you also need to apply for the GACC recommended registration process separately;
☼ What is the cost and timeline of GACC registrations?
Answer: Different type GACC registration have different cost and timeline;
1. General GACC registration fee for Exporters is $390 and application time within 7-8 days;
2. GACC registration fee for low and Medium-risk foods producers is $780 and application time within 2-3 weeks;
3. GACC registration fee for High-risk foods producers is $980 and application time within 1-2 months;
For details, please visit GACC registration cost
☼ We are manufacturer, our products export to China directly by us, How do I application for GACC registration?
Answer: You need to submit at least two GACC applications , one is GACC registration for Overseas Exporters,
the other is GACC registration for Overseas Manufacturer.
If your products involves medium-to-high-risk food category, you also need to apply anther recommendation application process of the competent authority of your country.
☼ I already have a manufacturer registration number, can I use this registration number to export other goods to China Customs?
Answer: Different food categories need to apply for different types of China GACC registration,
There are 3 types of GACC registration for Overseas Producers of imported food, Each type of GACC registration process, application document requirements, time and cost are different.
☼ I have 3 factories that belong to the same company and export the same products to China. Which factory should I submit for registration?
Answer: According to the requirements of the “GACC Decree 248: Regulations on the Registration and Administration of Overseas Producers of Imported Food”,
all overseas food manufacturers, processors, and storage facilities need to register with the GACC,
Each of the food category requires a separate GACC registration number, Each facility address requires a separate GACC registration number.
☼ What is an 18-digit registration number and what does it mean?
Answer: The below picture has clearly explained the meaning of each of the 18-digit GACC Registration Number Structure.
☼ What are the reasons cause GACC registration failure?
Answer: Some GACC applicants, want to save costs, do not entrust GACC Association to apply for GACC registration, but apply for GACC registration in the
“single window” by themselves, but lead to a high failure rate, and in the end, they still neet to entrust a professional GACC Association to solve the problem of GACC registration failure,
finally, they not only did not save costs, but also waste a lot of time, resulting in export delays and greater losses;
We often receive urgent enquiries from GACC applicants:
“We have submitted an application for GACC registration in the single window, and it has been a long time, but it has not been approved,
and we have received a response from GACC, what should I do?”
If the GACC registration application documents are correct, it will usually be approved by GACC in 1-2 weeks, or get GACC’s reply for corrective action,
if you have not received any reply from GACC, then there must be a problem in application process;
The most common reasons for registration failure are:
1. Wrong application type and category:
GACC registration is applied based on food categories. There are about 30 categories and 100 sub-categories in GACC-registered food categories.
Each sub-category needs to apply for a separate GACC registration number. If the products of the manufacturer involve multiple categories, then they need to apply for multiple GACC registration numbers;
Different food categories need to apply for different types of China GACC registration, There are 4 types GACC registrations:
- GACC registration for overseas manufacturers of Low risk food => GACC-I
- GACC registration for overseas manufacturers of Medium risk food => GACC-II
- GACC registration for overseas manufacturers of High risk food => GACC-III
- GACC registration for overseas exporters of imported food => GACC-E
2. Wrong classification for products listing :
GACC registration requires the listing of foods exported to China, and needs to fill in China’s HS code and CIQ code.
The classification rules of foods in China and the country of origin may be different. Wrong classification of foods will lead to failure of GACC registration;
3. Incorrect application documents:
Different types of GACC registrations for different food categories have different requirements for application materials,
The main application materials for GACC registrations include:
GACC registration application form
Business License for company
Production License for facility
Certificate of production management system
Recommendation letter from competent authority of country of origin (required for GACC-II, GACC-III types)
Enterprise Information Form
Enterprise Commitment Statement
Processing flow chart
List of foods to be exported to China
List of Major raw materials & affiliated company
Mandarin label element
These application documents need to meet the requirements of China’s regulations and national standards; and some application materials also require Chinese versions.
It is easy to make mistakes if you are not a professional in Chinese regulations;
If all application documents are not submitted, or, if some of the application documents do not meet the requirements of GACC, it may lead to the failure of GACC registration;
Moreover, if the applicant does not submit all the necessary application documents, the GACC will not start the review process,
but the applicant thinks that he has completed the application and waits for the GACC review, it will resulting in both parties waiting in vain, wasting time.