To implement General Secretary Xi Jinping’s important instructions on the "four strictest" requirements for food safety with and further strengthen full-chain supervision of imported food safety, the General Administration of Customs has renamed the Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food to Regulations of General Administration of Customs of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food.
On October 14, 2025, the General Administration of Customs promulgated the Regulations of General Administration of Customs of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food (HGZSL No. 280, hereinafter referred to as the “Regulations”), which will come into effect on June 1, 2026. To enable administrative counterparts and all sectors of society to comprehensively understand and accurately grasp the background and key content of this regulatory revision, the relevant issues are interpreted as follows:
I. Background and Purpose of Revision
The current Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food has been implemented since January 1, 2022, playing an important role in comprehensively implementing the requirements of the Food Safety Law of the People's Republic of China on the registration of overseas manufacturers of imported food, strengthening source supervision of imported food, and serving the overall situation of national diplomacy and foreign trade. However, with the continuous expansion of China's opening-up, the trade volume of imported food and the number of registration applications from overseas manufacturers have grown rapidly, making it necessary to further improve the registration and administration system to better adapt to the requirements of "guarding the national gate and promoting development."
II. Key Issues to Be Explained
(1) Clarify Risk Management Principles to Enhance Scientific and Precise Registration and Administration
Clarify that customs applies risk management principles, implementing corresponding registration methods, review procedures, and other registration and administration requirements based on the assessment and review of the food safety system and food safety conditions of countries where overseas food manufacturers are located, combined with the risk level of related foods (Articles 5, 12, 19, etc.). Meanwhile, adjust the 18 categories of officially recommended registered foods listed in the current regulations to catalog-based management, facilitating dynamic adjustment based on changes in risk levels (Article 6).
(2) Adhere to Bottom Line of Food Safety Supervision, Adjust and Optimize Registration Methods
Fully incorporating opinions from WTO members, the current two registration methods of "competent authority recommendation" and "enterprise application" are optimized to be all applications submitted by enterprises. For foods included in the catalog of imported food requiring official recommendation for registration, enterprises still need to submit inspection reports and recommendation letters issued by competent authorities when applying for registration, ensuring that the food safety bottom line is not relaxed (Article 9). Meanwhile, conducting more in-depth and extensive international cooperation in the field of the registration and administration for imported food manufacturer, a more convenient list registration method is added. For countries (regions) that have signed food safety cooperation documents with China, their competent authorities can provide the list of enterprises, and the General Administration of Customs implements batch registration and administration for enterprises on the list according to bilateral agreements (Article 17).
(3) Extend Whole-Chain Supervision Requirements to Enhance International Co-Governance of Food Safety
For the list-based registration method, it is clarified that the food safety management system of the country (region) should be recognized by the General Administration of Customs, while stipulating that competent authorities should provide a statement that recommended enterprises meet registration requirements and commit to continuously fulfilling bilateral agreed responsibilities (Articles 17, 18). It is clarified that for all enterprises that no longer meet registration requirements, competent authorities of their countries (regions) should supervise and urge them to make rectification, and issue supervision rectification reports and a written statement of meeting registration requirements after rectification completion (Article 25).
(4) Further Tighten Post-supervision Management Requirements
Improve the circumstances for registration revocation. It is clarified that enterprises "granted registration despite lacking application qualifications or not meeting registration conditions" should be revoked (Article 27). Improve "non-acceptance of registration" circumstances, stipulating that for countries (regions) whose food imports are legally suspended by the General Administration of Customs, registration applications from related food enterprises in those countries will not be accepted during the suspension period (Article 28).
(5) Further Optimize Registration and Administration Process
Considering the actual supervision situation of various countries (regions), accept "certificates issued" by overseas competent authorities as enterprise identity certificates (Item 2, Paragraph 1 of Article 9). Add automatic registration renewal provisions for enterprises, further simplifying the management measures for enterprise renewal of registration (Article 21). Improve enterprise registration renewal procedures, relaxing the application renewal period from "3 to 6 months" before expiration to "3 to 12 months" before expiration, providing enterprises with sufficient time (Article 22).
According to the Agreement on Technical Barriers to Trade and other relevant regulations, except for emergency measures, members should allow a reasonable time interval between the promulgation and effectiveness of new technical trade measures, generally not less than 6 months. Therefore, the newly revised Regulations provides a sufficient transition period and will officially come into effect on June 1, 2026.
(Contributed by: Department of Legal Affairs, Bureau of Import and Export Food Safety)
Disclaimer：The above content is translated from Chinese version of GACC. The GACC version shall prevail.
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