On October 14, 2025, the General Administration of Customs of the People’s Republic of China (GACC) issued the Regulations on the Registration Management of Overseas Production Enterprises of Imported Food (hereinafter referred to as “Decree No. 280”), which will take effect on June 1, 2026.
CIRS Group compared Decree No. 280 with the current regulations (hereinafter referred to as “Decree No. 248”) and identified the key changes as follows.
1. The official recommended registration food catalog is yet to be announced, and the favorable policies exempting health foods and special dietary foods from official registration remain undetermined
Decree No. 280 has not officially released the catalog of imported foods requiring official registration. However, in the draft for public consultation issued by the GACC in January, health foods and special dietary foods were not included in the official recommended catalog. If this catalog is formally implemented, the registration cycle and difficulty for related products entering the Chinese market are expected to be reduced, which would be a significant benefit for consumers and the market. CIRS Group will closely monitor the release of the official recommended registration food catalog.
2. Add a new list registration approach, eligible enterprises on the approved list may apply for batch registration
According to Decree No. 280, if the food safety management system of the country (or region) where an overseas food manufacturer is located has been recognized by the GACC, and one of the specified conditions is met, the competent authority of that country (or region) may submit to the GACC a list of food manufacturers recommended for registration in China along with other application materials. After review, the GACC will register the enterprises that meet the requirements and assign them a registration number for operation in China.
3. Functional upgrade: Automatic renewal upon expiry of registration validity
Decree No. 280 introduces an automatic renewal feature. When the registration validity period of enterprises that meet the requirements set by the GACC expires, the registration will be automatically renewed for another five years.
However, it should be noted that certain imported food categories will not be eligible for automatic renewal. The list of such products will be separately announced by the GACC. For these types of food, enterprises must submit a renewal application to the GACC between 3 and 12 months prior to the expiration of their current registration.
4. Clarifying the registration requirements for specific situations, such as a single storage enterprise and cross-border e-commerce retail
Decree No. 280 makes clear provisions for the following situations:
1) The scope of overseas storage enterprises for imported food that need to be registered in accordance with the new regulations shall be separately announced by the GACC.
2) The registration of overseas production enterprises of primary edible agricultural products shall be separately formulated by the GACC.
3) The management requirements of overseas food production enterprises for cross-border e-commerce retail import shall be handled in accordance with relevant regulations.
5. CIRS’s Perspective
The introduction of the new regulation represents an optimization and improvement of the existing system by the GACC amid the continuous expansion of import trade. It provides more convenient registration conditions and a more rational management approach for imported food.
In particular, for health foods, if official recommendation for registration is no longer required, this change will not only shorten and simplify the registration process but also enhance the confidence of overseas health food enterprises, potentially stimulating greater enthusiasm among foreign companies to apply for the import registration of health foods in China.
About CIRS Group
Established in 2012, the Food Business Division of CIRS Group has helped over 1,000 domestic and international food companies achieve one-stop compliance solutions. CIRS offers a full range of regulatory services covering novel food applications, synthetic biology-derived foods, U.S. GRAS notice, EU novel food application, health food registration, and food for special medical purposes (FSMP).
Our food services in China include, but are not limited to:
- China FCM Testing
- China new food raw materials registration
- China new food additive registration
- China health food (dietary supplement) registration/filing
- China health food testing service
- China new food contact substance registration
- China food for special medical purpose (FSMP) registration
- China infant formula milk powder registration
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
