Declaration draft for registration of Chinese food overseas enterprise registration

According to the “Recommended Registration of Food Manufacturers Exporting to Mainland China” announced by the Food and Drug Administration (TFDA) of the Ministry of Health and Welfare on October 14, 2021, in response to the notification from China – “Import and Export Food Safety Bureau of the General Administration of Customs of the People’s Republic of China” Rule No. 248, please go to the Food and Drug Administration’s “Integration of Hygiene and Safety for Food Distribution and Distribution” for those who wish to export and sell food (see Annex 1, 18 categories of food) to China (including supplements, additions, changes, extensions or cancellations). Management platform (referred to as the exporting and selling platform)” (http://fes.fda.gov.tw/index), after logging in with the credentials, download the relevant documents in the “Delivering Foods Zone”, and fill in the electronic file of the document in the column Bit upload, the Food and Drug Administration of the Ministry of Welfare and Welfare will submit it to the Chinese side for the review.

The Import and Export Food Safety Bureau of the General Administration of Customs of the People’s Republic of China promulgated Rule No. 248 (On the publication of the “Regulations of the People’s Republic of China on the Administration of Registration of Overseas Manufacturers of Imported Food”) and Rule No. 249 (On the publication of the “People’s Republic of China Import and Export Food Safety Administration” Producers and operators of food imported and exported to China shall engage in the production and operation of imported and exported food in accordance with the international treaties and agreements concluded or acceded to by China, Chinese laws and regulations and national food safety standards, and shall be subject to supervision and management in accordance with the law to ensure import and export. Food safety is responsible for the society and the public, and assumes social responsibility. It will be implemented from January 1, 2022. Therefore, if overseas enterprises importing food from China adopt the normal trade channel or the small three-way model or the project import model, they must apply for registration legally.

At the same time, the Food and Drug Administration updated the announcement on August 4, 2022. China has notified it on August 1, 2022. As of June 30, 2022, the registration supplementary information provided by some businesses that have obtained registration numbers in China If there are still deficiencies, if the enterprise is still willing to sell or sell, it can apply for supplementary documents online by itself. The Chinese side will retain the export qualification until August 31, 2022 before providing information.

In addition, the original enterprise applies for BC 9610 / BBC 1210 method of cross-border e-commerce import into China (not the above-mentioned normal trade or Mini Three-Link Transportation), in accordance with China’s e-commerce law, cross-border e-commerce. If the commercial law is regulated, there is no need to apply for the registration of overseas enterprises importing food from China. However, if it belongs to the 18 categories of food exported to mainland China, it must be recommended for registration by the competent authority where the country is located. Note 1 You can apply for the “Integrated Management Platform for Hygiene and Safety of Food Distribution and Marketing” online without any processing fee. 

*Supplementary explanation, because enterprise registration requires industrial and commercial certificates and cannot be entrusted to do so, it is recommended that enterprises apply online by themselves. If the company has products with raw materials from Japan, it is also required to attach the “The source of raw materials and the declaration on not from Japan’s 10 cities” Note 2. The declaration form can be downloaded and filled in by itself on the “Integrated Management Platform for Hygiene and Safety of Food Distribution”.

Note 1: The list of 18 categories of food that must be recommended for registration by the competent authority where the country is located is as follows:

meat and meat products casings
aquatic products dairy
Bird’s Nest and Bird’s Nest Products *honey products
Eggs and Egg Products Edible oils and oils
stuffed pasta edible grains
Grain Milling Industrial Products and Malt Fresh and dehydrated vegetables and dried beans
seasoning Nuts and Seeds
dried fruit Unroasted coffee and cocoa beans
*special dietary food *Healthy food

*honey products: Single formula honey products

*special dietary food: Special medical food, infant formula and complementary food

*Healthy food: If it has not obtained the China normal Import Three Certificates or the registration record of China National Food Health Brand (“blue hat”), it does not belong to the health food defined by China.

Note 2: The declaration on not from Japan’s 10 cities are Fukushima, Miyagi, Chiba, Ibaraki, Tochigi, Gunma, Yuno, Saitama, Niigata (excluding rice), Tokyo, etc.

References:

https://www.fda.gov.tw/TC/siteContent.aspx?sid=11901

https://fes.fda.gov.tw/index

http://jckspj.customs.gov.cn/spj/zcfg18/bmgz91/3625617/index.html

http://jckspj.customs.gov.cn/spj/zcfg18/bmgz91/3625580/index.html

http://jckspj.customs.gov.cn/spj/zcfg18/gfxwj65/4058583/index.html