This definitive guide provides foreign food companies with essential knowledge to successfully partner with Chinese importers and ensure regulatory compliance throughout the import process. Understanding these requirements is crucial for accessing China’s massive consumer market of over 1.4 billion people.
At AppInChina, we provide expert guidance to help foreign food companies navigate China’s complex import regulations and connect with qualified Chinese importers for successful market entry.
What Legal Framework Governs Food Imports to China?
The current regulatory structure is built primarily on four key laws and regulations:
The 249 Order represents a comprehensive update to China’s food import regulations, implementing the “Four Strictest” requirements for food safety and consolidating multiple previous regulations into a unified framework.
Who Can Import Food into China?
Only Chinese companies with proper business registration and import authorization can legally import food products into China. Foreign companies cannot directly import food and must work through qualified Chinese import partners.
Requirements for Chinese Food Importers:
Valid business license with food import and sales in business scope
Import/export business operation rights
Completed Food Importer Registration (进口食品进口商备案) with local customs
Automatic Import Licenses for restricted product categories (when applicable)
Must establish partnerships with qualified Chinese importers
May establish Wholly Foreign-Owned Entity (WFOE) if they want to handle imports directly
What is the Food Importer Registration and Why is it Required?
Food Importer Registration (进口食品进口商备案) is the foundational requirement for all Chinese companies engaged in food imports. This registration establishes the legal basis for importing food products and must be completed before applying for any specific import licenses.
Processing Authority: Local customs offices where the importer’s business is registered
Processing Time: 5 working days (both legal and committed timeframe)
Cost: Free of charge
Validity: Ongoing, with updates required for business changes
Eligibility Requirements: Companies planning to engage in food import business must demonstrate appropriate business scope, organizational capacity for food safety management, and compliance with relevant regulations.
What Documentation is Required for the Food Importer Registration?
The Import Food Importer Registration process requires comprehensive documentation demonstrating business qualifications and food safety management capabilities.
Initial Registration Documents:
Food Importer Registration Application Form
Original document with company seal
Complete company information and intended food categories
Registration Change Requirements: Any changes to business scope, organizational structure, or food categories require updated registration through submission of revised application forms with company seal.
How Do You Apply for Food Importer Registration?
The application process for Import Food Importer Registration involves systematic steps through designated government channels.
Application Process Steps:
Application Submission: Companies submit registration applications to their local supervising customs authority
Review Process: Local customs authorities review applications and approve qualifying submissions
Publication: Approved companies are published on official customs lists
Corrections: Non-compliant applications are returned to companies for modification and resubmission
Application Methods:
Online Application: Available 24/7 through China’s “Single Window” (一窗通) international trade platform or “Internet + Customs” (互联网+海关) system
In-Person Application: Submit at local customs business windows during working hours (8:30-17:00 on working days)
What are Automatic Import Licenses and When are They Required?
Automatic Import Licenses (自动进口许可证) are required for specific food categories considered strategically important or sensitive for China’s food security. These licenses are issued by the Ministry of Commerce (MOFCOM) and represent an additional requirement beyond basic importer registration.
Products Requiring Automatic Import Licenses:
Meat Products: Beef, pork, lamb, chicken and related meat products
Dairy Products: Milk and milk powder products
Agricultural Commodities: Soy bean and bean products, canola seed products
Strategic Categories: Additional products as specified in the annual Automatic Import License Management Catalog
License Characteristics:
Validity Period: 6 months within the calendar year
Extension Options: Special procedures available when needed
Application Authority: Ministry of Commerce (MOFCOM) or designated provincial commerce departments
Processing Time: Typically 15-30 working days depending on product category and complexity
How Do You Obtain Automatic Import Licenses?
The Automatic Import License application process requires comprehensive business documentation and justification for import necessity.
Application Requirements:
Valid business registration with import/export scope authorization
Completed automatic import license application forms
Import necessity justification and detailed business plans
Financial capability documentation and credit verification
Previous import experience records and compliance history
Application Process:
Requirement Verification: Check current Automatic Import License Management Catalog for product categories
Documentation Preparation: Gather all required business and product documentation
Application Submission: Submit through designated provincial commerce departments or directly to MOFCOM
Review and Approval: Undergo comprehensive review including business capacity assessment
License Issuance: Receive license with specific validity periods and usage conditions
Strategic Considerations: Companies should apply well in advance of intended import activities, as processing times can vary significantly based on product complexity and market conditions.
What is the Complete Food Import Process Step-by-Step?
Successfully importing food into China requires managing a comprehensive multi-phase process involving preparation, registration, licensing, documentation, and customs clearance procedures.
Phase 1: Pre-Import Preparation and Qualification
Company Qualification Confirmation:
Obtain valid business license with food import and sales in business scope
Secure import/export business rights and related authorizations
Complete registration with customs and inspection/quarantine authorities
Establish food safety management systems and organizational structures
Regulatory Knowledge Development:
Master China’s Food Safety Law and implementation regulations
Document Exchange: Exchange shipping documents for delivery orders upon cargo arrival
Initial Documentation Review: Verify all required documents are complete and accurate
Inspection Declaration Process (报检):
Submit inspection forms and supporting documents to inspection/quarantine authorities
Provide certificates of origin, health certificates, label samples, packing lists, and invoices
Inspection authorities verify document-cargo consistency and conduct initial sampling
Processing time: typically 3-5 working days for clearance certificate issuance
Customs Declaration Process (报关):
Submit customs declaration forms after obtaining inspection clearance certificate
Customs authorities review pricing, classification, and origin information
Complete tax assessment and payment based on customs valuation
Processing time: approximately 5 working days for tax notice and clearance
Physical Inspection and Verification:
Risk-based physical inspection of imported food products
Verification of quantity, specifications, and packaging against declarations
Additional sampling for laboratory testing when required
Release Authorization:
Goods released after completing all inspection/quarantine and customs procedures
Tax payment completion required before final release
Importers collect goods with official release notification
Phase 7: Final Inspection, Testing, and Label Verification
Official Inspection and Sampling Procedures:
Transport goods to designated food supervision warehouses
Inspection authorities conduct comprehensive examination and sampling
Representative samples sent to authorized laboratories for testing
Comprehensive Laboratory Testing:
Testing for microorganisms, heavy metals, additives, and safety indicators
Verification of nutritional content and ingredient accuracy
Testing period: typically 15-20 working days for complete analysis
Label Compliance and Rectification:
Review of actual product labeling against approved specifications
Correction of any non-compliant labeling issues under customs supervision
Re-labeling of products until full compliance achieved
Final verification of corrected labeling
Phase 8: Health Certificate Issuance and Market Authorization
Final Certification Process:
Import health certificate issued after successful inspection and testing completion
Certificate confirms products meet domestic consumption standards and safety requirements
Documentation required for legal market entry and sales authorization
Integration with distribution and retail systems
This comprehensive eight-phase process demonstrates why partnering with experienced, qualified Chinese importers is essential for foreign food exporters targeting China’s market. These steps may vary depending on the nature of the food you are importing. If you would like to know more about your specific case, contact us with any questions.
What are the Key Differences Between GACC Registration and Chinese Import Requirements?
Understanding the distinction between foreign facility requirements and Chinese importer obligations is crucial for successful food import operations.
Who Obtains It: Foreign manufacturers and exporters (companies outside China)
Purpose: Registers overseas production facilities with Chinese customs authorities
Application Process: Foreign companies can apply directly through GACC systems
Coverage: Facility approval and product category authorization for export to China
Requirement: Registration code must appear on all product packaging and documentation
Chinese Import Requirements (Chinese Importer Responsibility):
Who Obtains Them: Chinese companies with import business scope (companies inside China)
Purpose: Authorizes Chinese companies to legally import specific food categories
Application Process: Chinese companies apply through local customs and MOFCOM systems
Coverage: Import authorization and market entry permissions for Chinese territory
Requirements: Importer registration plus automatic licenses for restricted categories
Coordinated Compliance Model: Both requirements work together as a “dual-key system” where foreign facility approval (GACC registration) and Chinese import authorization (importer registration/licenses) must be satisfied simultaneously for successful food imports.
What Challenges Do Foreign Companies Face?
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Foreign food exporters commonly encounter several challenges when navigating China’s import requirements, but these can be effectively managed with proper planning and professional support.
Documentation and Regulatory Complexity: The multi-layered regulatory requirements can overwhelm companies new to the Chinese market. Solutions include working with experienced Chinese import partners who understand current requirements, developing standardized documentation templates and compliance checklists, and engaging qualified regulatory consultants for complex product categories.
Language and Communication Barriers: Regulatory documentation and procedures are conducted in Chinese, creating potential communication issues. Effective approaches include partnering with bilingual professionals, such as AppInChina, who understand both regulatory requirements and business needs, utilizing qualified translation services for critical documents, and maintaining clear communication protocols with Chinese partners.
Timeline and Process Coordination: Managing multiple approval processes simultaneously requires careful coordination and planning. Best practices include developing comprehensive project timelines with appropriate buffer periods, establishing clear communication protocols with all stakeholders, and maintaining backup options and contingency plans for potential delays.
How Much Does Food Import Compliance Cost?
Understanding the comprehensive cost structure for food import compliance helps foreign companies budget effectively and make informed market entry decisions.
Direct Regulatory Costs:
Import Food Importer Registration: Free of charge (processed by Chinese importers)
Automatic Import Licenses: Government fees vary by product category
Label Registration: Fees vary by number of products and complexity
Inspection and Testing: Charges based on product type and testing requirements
Professional Service Costs: Many operations require professional assistance including regulatory consultants for compliance guidance, legal advisors for contract and regulatory issues, translation services for documentation requirements, and customs brokers for clearance procedures.
Operational and Ongoing Costs: Sustainable operations involve costs for compliance monitoring and maintenance, quality control systems and procedures, relationship management with Chinese partners, and contingency planning for regulatory changes.
Strategic Cost Considerations: While regulatory compliance costs represent a significant investment, they should be evaluated against the substantial market opportunity China represents. Professional compliance management often reduces long-term costs by avoiding delays, rejections, and regulatory penalties.
How Can AppInChina Help with Food Import Success?
AppInChina provides comprehensive support services designed to help foreign food companies successfully navigate China’s complex import requirements and establish sustainable market presence. We can help you by:
Providing you with a free consultation outlining what you need to obtain full compliance to import into China
Acting as the Chinese entity through which your products will be imported, otherwise known as 进口商 in Chinese.
Distributing and promoting your products through the biggest digital retailers such as Taobao (淘宝) and JD (京东).
Distributing your products to relevant brick and mortar retail shops across China.
If you want to bring your food products to China but don’t know where to start, contact us to get started!