Cross-border Food Retail Imports Temporarily Exempt from GACC Registration

The Administrative Provisions on the Registration of Overseas Manufacturers of Imported Food of the People’s Republic of China (GACC Decree No. 280) (hereinafter referred to as “Decree 280”), issued by the General Administration of Customs of China, was promulgated on October 14, 2025, and will take effect on June 1, 2026.

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On March 18, 2026, the GACC released implementation details related to Decree 280, including a series of supporting catalogs and lists. A summary is provided below:

1. Recommended Registration Catalog: 17 Categories

The newly released catalog of imported foods requiring official recommendation for registration includes 17 categories. Compared with the current Decree 248, several primary agricultural products have been removed, such as oilseeds, fresh vegetables, dried beans, and unroasted coffee and cocoa beans. Producers of these removed categories are no longer subject to Decree 280. Previously, the GACC issued Announcement No. 219 (2025) on the declaration management of overseas enterprises for imported agricultural products, ensuring a seamless regulatory transition.

Notably, for foods included in the recommended registration catalog, enterprises may directly submit applications to Chinese authorities after obtaining an inspection report and recommendation letter from the competent authority, without requiring the authority to submit the application on their behalf.

Table 1. Comparison of Recommended Registration Catalogs

Decree 280 (New)	Decree 248 (Current)
Meat and meat products, casings, bird’s nest and products, bee products, eggs and egg products, edible oils and fats, stuffed flour products, edible grains, grain milling products and malt, dehydrated vegetables, seasonings, nuts and seeds, dried fruits, foods for special dietary uses, health foods, dairy products, aquatic products	Meat and meat products, casings, aquatic products, dairy products, bird’s nest and products, bee products, eggs and egg products, edible oils and oilseeds, stuffed flour products, edible grains, grain milling products and malt, fresh and dehydrated vegetables and dried beans, seasonings, nuts and seeds, dried fruits, unroasted coffee and cocoa beans, foods for special dietary uses, health foods

2. List of Foods Not Eligible for Automatic Renewal

This list includes two categories of “meat and meat products”, and “bird’s nest and related products”. Relevant manufacturers must apply for renewal registration through the application process 3–12 months before the expiration of their registration validity.

3. Overseas Storage Facilities Subject to Registration

According to the imported food overseas manufacturer registration system, standalone overseas storage facilities do not require registration. However, the new announcement clarifies that registration is required for cold storage facilities used to store terrestrial animal-derived foods and aquatic products.

4. Import Declaration Requirements

For enterprises requiring official recommendation: Products manufactured within the validity period of registration may be declared for import.
For self-registered enterprises: Registration must remain valid at the time of import declaration.
For suspended, revoked, or canceled enterprises: Products shipped before such regulatory actions remain eligible for import declaration.

5. Requirements for Cross-border E-commerce Retail Imports

The announcement clarifies that imported foods entering China as goods for human consumption or as food processing materials must declare the overseas manufacturer’s China registration number. However, cross-border e-commerce retail imports are not regulated as goods but as personal-use items. Therefore, based on this distinction, such products are currently not required to complete overseas manufacturer registration.

The GACC will implement dynamic management of the relevant catalogs, lists, and scopes, making periodic adjustments based on food safety data, consumer demographics, and international practices. The release of these supporting documents provides clear operational guidance for implementing the new regulation. Continuous monitoring of policy updates will be essential for ensuring compliance and facilitating smooth registration processes in China.

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