Export Guide: Policies for Eggs and Egg Products

 

 

As a leading global exporter of egg products, China supplies a diverse range of international markets. The article provides an analysis of the critical stages in the export process for eggs and egg products, detailing the compliance requirements under prevailing regulations.

I. Understanding Egg Product Categories

The scope of "eggs and egg products" encompasses fresh eggs and their processed derivatives destined for human consumption. Processed egg products are primarily categorized into four distinct types: liquid, dried, frozen, and further-processed eggs.

Liquid Egg Products: Produced by shelling and processing fresh eggs. Key products include liquid whole egg, liquid egg yolks, and liquid egg whites.

Dried Egg Products: This category comprises products made from fresh eggs that undergo breaking, filtering, pasteurization, and are then finished by either spray drying or through a fermentation followed by drying. Key products include whole egg powder, egg yolk powder, and egg white (albumen) flakes or powder.

Frozen Egg Products: Produced by processing fresh eggs followed by freezing, this category includes frozen whole egg, frozen egg yolk, and frozen egg white.

Further-Processed Eggs: This final category comprises egg products where fresh eggs, with or without additional ingredients, are cured using methods such as salting, alkalization, fermentation in rice wine, or stewing in spiced brine. Key products include century eggs, salted eggs, separated salted egg yolks, fermented rice wine eggs, and spiced braised eggs.

II. Key Qualifications for Egg Product Exporters

(I) Export Food Producer Registration

Applicants should submit an application online via the integrated online service platform of "Internet plus Customs" (http://online.customs.gov.cn) or the China International Trade Single Window(https://www.singlewindow.cn) to their local competent Customs authority. The required documents, including theExport Food Producer Registration Form, must be uploaded accordingly.

Upon review, the local competent Customs authority will issue the official Export Food Producer RegistrationCertificate to applicants who provide a complete set of materials that fulfill all statutory requirements.

(II) Export Breeding Farm Registration

Applicants should submit an application online via the integrated online service platform of "Internet plus Customs" (http://online.customs.gov.cn) or the China International Trade Single Window (https://www.singlewindow.cn) to their local competent Customs authority.The following documents must be uploaded accordingly:

1. Application Form for Registration of a Farm Supplying Eggs for Export;

2. Proof of Legal Entity Status;

3. Animal Epidemic Prevention Qualification Certificate;

4. Animal Health and Epidemic Control Protocols, covering daily hygiene management, disease prevention and control, and medication administration;

5. Breeding Management Protocols, governing the use of feed and additives, as well aslive poultry access control;

6. A situational map of the farm within its administrative divisions, and a detailed site plan indicating gates, poultry houses, living quarters, water sources, feed storage, and veterinary product storage.

Upon acceptance, local competent Customs authority will review the application and grant registration if all requirements are satisfied.

(III) Overseas Market Registration (Recommended by Authorities)

When a foreign market requires an official recommendation from Chinese Customs for market entry, the exporting enterprise must apply for it through its local Customs authority. This "recommended registration" process is specifically for Chinese exporters of eggs and egg products whose target countries or regions mandate such an official endorsement.

Applicants are required to submit their application - and are responsible for the authenticity of all supporting documents - to their local customs authority via the Administrative Counterpart Unified Management Subsystem (Version 3.0), accessed through the integrated online service platform of "Internet plus Customs" or the China International Trade Single Window. The required documents are as follows:

1. Application for Registration of an Export Food Producer in Overseas Markets;

2. Self-Assessment Checklist for an Export Food Producer’s Registration in Overseas Markets;

3. Details on Production Facilities and Processes, including but not limited to factory layout, workshop floor plan, personnel and material flow diagrams, water and air flow diagrams, as well as photographs of key processing stages;

4. Documentation of the company’s traceable food safety and hygiene control system;

5. Any additional supporting materials specified by the importing country or region.

Upon receiving an application, the local competent Customs authority should review it, taking into account the company’s credit standing, its oversight and management history, and its food safety performance in export operations. Enterprises that satisfy all requirements will be formally recommended to the competent authorities of the importing country or region.

III. Navigating Customs Clearance for Export

(I) Export Declaration Process

The exporter or their authorized agent shalldeclare toCustoms authority through China International Trade Single Window. The declaration must be accompanied by all requisite commercial documents (such as the commercial contract, invoice, transport documents, and packing list), the necessary export licenses and supporting documentation, as well as any otherimport or export documents specified by the General Administration of Customs. Such documents are submitted electronically to Customs by the declarant via the paperless clearance system.

(II) Clearance and Release of Goods

1. Release after Document Check: If the system does not flag the shipment for inspection, Customs should review the submitted declaration and supporting documentation. Upon verifying compliance, the goods are cleared for release.

2. Release after Physical Inspection: If the system flags the shipment as "requiring inspection", the Customs office at the place of origin or cargo consolidation will perform an on-site examination as per the inspection instructions. For egg products, this typically involves checks on sensory attributes, hygiene conditions, specifications, packaging, quantity, weight, and the presence and accuracy of shipping marks and product labels. Upon verifying compliance, the goods are cleared for release.

3. Release after Inspection and Laboratory Testing: If the system flags the shipment as "requiring inspection and testing," Customs should conduct a document review, a physical inspection, and collect samples for laboratory analysis. The goods are released only after all checks return satisfactory results.

Upon successful completion of any required on-site inspection or supervised sampling, Customs should issue the relevant export certificates, authorizing the shipment to proceed.

IV. Addressing Key Market Technical Specifications

Exporters of eggs and egg products must ensure their goods meet the standards of the destination market or specific contractual terms. Where international treaties or agreements to which China is a party contain specific provisions, those treaty or agreement obligations take precedence and must be complied with. If no standards are set by the importing country or region, stipulated in the contract, or required by applicable international treaties or agreements mentioned above, then the exporting enterprise must ensure that its eggs or egg products comply with China’s national food safety standards. The key technical considerations for major export destinations are outlined below.

(I) Export to EU: Regulatory Requirements

1. The EU prohibits the import of fresh eggs for retail sale from China, as stipulated in Article 10(6) of Regulation (EC) No 2160/2003. Consequently, only processed egg products are eligible for export.

2. For egg products, specific animal health protocols - particularly those addressing highly pathogenic avian influenza and Newcastle disease - must comply with Regulation (EU) 2020/692.

3. The production and processing of egg products must adhere to the general hygiene requirements for food business operators, outlined in Annex II of Regulation (EC) No 852/2004, and the specific hygiene requirements for eggs and egg products, set out in Annex III of Regulation (EC) No 853/2004.

4. Egg products exported to the EU must satisfy the requirement for mark set out in Annex II of Regulation (EC) No 853/2004 and the microbiological safety criteria established by Annex I of Regulation (EC) No 2073/2005.

5. Furthermore, egg products exported to the EU must also comply with Commission Decision 2002/994/EC, which mandates pre-export testing for residues of the veterinary drugs such as chloramphenicol, nitrofurans, and their metabolites.

(II) Export to Canada: Regulatory Requirements

For products such as salted or century eggs, exporters to Canada must submit a Zoosanitary Export Certificate with each shipment, in accordance with the Safe Food for Canadians Act (SFCA) and theSafe Food for Canadians Regulations (SFCR). The Canadian importer is also required to possess a valid Safe Food for Canadians Licence.

The Zoosanitary Export Certificate must be issued and signed by an official veterinarian of the exporting country, containing the following declarations:

1. All egg products originate from healthy flocks free from velogenic Newcastle disease and highly pathogenic avian influenza (fowl plague).

2. Eggs were inspected prior to processing and were free from visible surface contamination.

3. One of the following conditions is met: the eggs have been candled to confirm the absence of embryos, blood clots, and blood spots; or they originate from commercial laying flocks without roosters and are therefore embryo-free. (Delete as applicable).

4. Depending on the product, the following curing method applies: century eggs ("preserved eggs ") must be soaked in a solution containing water and tea leaves, salt, quicklime, or alkali for a minimum of 45 days; or, salted eggs must be wrapped in a mixture of straw or wood ash, water, and salt for at least 30 days. (Delete as applicable).

5. Wrapping materials must contain no soil. All packaging materials must be new, clean, and free of soil, hay, straw, or feed.

6. Frozen salted egg yolks must be sourced from salted eggs that have been wrapped and cured for no less than 30 days. The yolks must be frozen and the packaging clean.

(By Chen Wenjia)