GACC FAQs: Is It Necessary to Submit the Registration/Filing Certificate for Imported Health Foods?

Recently, CIRS Group has received numerous inquiries from health food companies regarding the registration of overseas manufacturing enterprises in China. Many companies have reported that when applying to the General Administration of Customs for registration in China (GACC), they are required to submit the registration certificate/filing certificate for health food; some companies have also reported that health foods imported through cross-border e-commerce are also required by customs to submit the registration certificate in China. In response to this, the food department at CIRS Group has conducted extensive verification and now summarizes the conclusions as follows.

1. GACC Registration: The health food registration certificate/filing certificate is indeed a key material

The above image shows the operation interface of the registration management system for overseas production enterprises of imported food. Under the category of [Health Food], there is a material requirement named [Registration or Filing Certificate for Health Food with Relevant Departments in China], which is displayed in the system as non-mandatory, meaning it is voluntarily provided.

CIRS Group consulted the GACC, and received the following response: Although this material is not mandatory, enterprises are encouraged to provide it whenever possible. If it is not submitted and GACC considers it necessary to verify the authenticity and consistency of the application materials, the registration application may be returned, and the company will be requested to provide the relevant certificates in the feedback comments.

Health foods fall under the category of foods that require recommendation and registration by the competent authority. The review timeline is affected by multiple factors and is generally lengthy. Once supplementary materials are requested, the overall timeline becomes even more unpredictable. Therefore, CIRS Group recommends that importers of health foods complete product registration or filing in China before applying for the overseas manufacturer registration with GACC. Otherwise, product customs clearance may be seriously delayed, resulting in unnecessary losses.

Cross-border E-commerce: Tightening Policies and Higher Compliance Thresholds

According to GACC Decree No. 280, which will come into effect on June 1, 2026, overseas manufacturers of imported foods sold through cross-border e-commerce retail shall comply with relevant management requirements. At present, products imported under the cross-border e-commerce are not required to complete overseas manufacturer registration in China.

However, influenced by the Youthit incident*, China’s regulatory attitude toward health foods sold via cross-border e-commerce has become increasingly cautious. CIRS Group was previously invited to attend an exchange meeting organized by the Canadian Trade Office, where representatives from the Yiwu government and other organizations also participated. During the meeting, the Yiwu authority mentioned that, in order to prevent negative incidents such as “fake foreign-brand products” from happening again, cross-border e-commerce policies may be further tightened.

It is foreseeable that customs clearance documentation requirements for health foods imported through cross-border e-commerce will become stricter, and the possibility of mandatory GACC registration in the future cannot be ruled out.

Whether it is GACC registration or health food registration and filing, product compliance remains the core prerequisite. CIRS Group has extensive experience in regulatory compliance and registration services and has successfully assisted dozens of domestic and overseas health food companies in obtaining product approval certificates efficiently.

To help companies respond to these policy changes, CIRS Group, together with HPA-Global, is to host a free webinar on the Policy Trends in Cross-Border E-Commerce for Imported Health Foods & Blue Hat Registration and Filing on Wednesday, August 12, 2026, at 12:00-13:00 EST. Please click here for more details.

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, feed and pet food, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

The vast majority of team members in CIRS Food Business Division have over 10 years of professional experience in food compliance, with more than 80% hold Master’s or Doctoral degrees in food-related disciplines. The CIRS toxicology expert team consists 24 Chinese Certified Toxicologists (DCST), 2 American Board Certified Toxicologists (DABT), and 2 European Registered Toxicologists (ERT). CIRS has provided one-stop food compliance services to over 1,000 domestic and international food and related enterprises. Leveraging its technical expertise, diverse resources, and global network, the CIRS Food Business Division offers global food compliance services, including but not limited to:

• Health food registration and filing in China;
• Application for “Three New Foods (new food additives, new food raw materials and new food-related products” in China;
• U.S. GRAS, NDI, and CAP notifications;
• EU Novel Food, food additives, and food enzymes applications; and
• Application for new feed ingredients and feed additives in China, the U.S., and the EU.

*Youthit incident

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.