!ALERT! MPI Notice: China’s New Regs For Manufacturer Registration And Import/Export Food Safety

MPI has released the following for distribution with members. Natural Health Products NZ’s Technical and Regulatory Sub-Committee is reviewing the implications of this notice for our sector. We will be participating in MPI’s cross commodity project team and keep members updated as necessary:

The General Administration of China Customs (GACC) has published their new regulations for both registration of overseas manufacturers of imported food (Decree 248) and import and export food safety (Decree 249).

Both were notified to the WTO SPS Committee in 2020, and both come into effect on 1 January 2022. MPI is currently comparing the differences between these regulations and previous regulations, and analysing any impact they will have on New Zealand’s market access.

Download the two tables which compare each of the new regulations with the previous regulations:

GACC Decree 249 – Administrative Measures on Safety of Import and Export Food of China – Comparison table against 2018 regulation (April 2021)
GACC Decree 248 – Administrative Measures on Registration of Overseas Manufacturers of Imported Food to China – Comparison table against 2012 regulation (April 2021)

Please note that the translation from Chinese to English in these tables is not an official MPI translation and users should use their own resources to ensure accuracy.

Although the new registration regulation requires ‘registration of all foods’ (except food additives), only about 20 types of food will need to be registered via MPI. All other foods will require the producer to self-register.

MPI has sought clarification from GACC on whether establishments currently registered by GACC will have their registration automatically extended to 5 years (the registration period in the new regulations – changed from the current 4 year period). GACC has advised MPI that a detailed arrangement around implementation has not yet been determined.

MPI hopes to commence a project in June 2021 so we can ensure that we meet the 1 January 2022 deadline for the registration regulation. We are currently working to this deadline as GACC has not confirmed whether there will be a transition period.

We hope to have a cross commodity project team which will include industry bodies. Our preliminary analysis indicates that some of the objectives of a cross-commodity project team would be:

  • to facilitate a more effective response to GACC’s implementation requirements once these are notified,
    to ensure that MPI can provide the necessary regulatory information for establishments that are regulated under the Animal Products Act and Food Act,
  • to consider smart ways to collect information from establishments and minimise transaction errors,
  • to ensure that there is minimal impact on existing trade, and
  • to ensure that there are opportunities for future new trade.

We will let you know about the project team in several weeks.

Any updates to requirements will be provided by MPI in terms of a FYI (guidance) or an OMAR notification once we have more information.

Please direct any queries through to [email protected].