EXPORTS IN CHINA Decrees 248/249: NEW REQUIREMENTS AND Registration of food product companies

The People’s Republic of China announced starting on the 1st of January 2022, the Decrees n. 248 and n. 249 issued by the General Administration of Chinese Customs (GACC).

The decrees introduce new requirements regarding food products imported from foreign countries, and impose particular obligations on all foreign producers of food products to be exported in China.

Action for Canadian companies

• It is critical that Canadian establishments register with GACC in the CIFER system prior to export. This includes, fish/seafood processing vessels involved in the manufacture, processing, and cold storage of food products that are exported to China. The CIFER system and the registration requirements are administered by GACC. GACC's new registration process is required in order for foreign establishments to maintain or obtain access to the Chinese market for food products. Once registered in CIFER, establishments need to ensure their shipments meet the label requirements of Decree 249. Key changes include that foods must be labelled on the inner and outer packaging in Chinese, or Chinese and English (Decree 249, Article 30) and bear either the CFIA-issued establishment ID number or the GACC-issued registration number. The GACC-issued registration number will be assigned to the establishment in the CIFER system and begins with the letters "CCAN".
High-risk products For Canadian establishments on existing eligibility lists for " high-risk" products, GACC already created their CIFER profiles and logins; these companies remain eligible to export. However, the management of new registrations and amendments is now entirely done in CIFER. Establishments must confirm their information in CIFER and update it and/or correct any errors. Amendments to existing registrations (for example, add a product) require establishments to complete a registration package in CIFER for verification by CFIA, followed by CFIA submission to GACC. New establishments must contact their local CFIA office and create a CIFER profile and login, before an application process can begin.
Medium-risk products In October 2021, the CFIA compiled basic profile information submitted by Canadian "medium-risk" product establishments. CFIA assigned unique identification numbers (where necessary) and transmitted lists of recommended establishments for medium-risk product types to GACC. Establishments must confirm their information in CIFER and update it and/or correct any errors. Amendments to existing registrations (for example, adding a product) require establishments to complete a registration package in CIFER for verification by CFIA, followed by CFIA submission to GACC. New establishments must contact CFIA to request CFIA creation of a CIFER profile and login, before an application process can begin. "Medium-risk" food product establishments which missed the October 2021 submission and who are planning to export to China should contact their local CFIA inspection office.
Low-risk products All food and agri-food products for export to China, other than "high-risk" and/or "medium-risk" products described above, are considered "low-risk" products by China and must self-register directly with CIFER. Note: GACC has advised that establishments which have previously registered for "high-risk" or "medium-risk" and also export "low-risk" products, do not need to self-register again.

As a result of the registration procedure, an appropriate identification code will be obtained and it must be indicated on each inner and outer packaging of the food.