China Issues Revised Rules for Overseas Food Manufacturer Registration

On October 14, 2025, the General Administration of Customs of the People’s Republic of China (GACC) officially promulgated the “Regulations of the People’s Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food” (GACC Order No. 280, the “Regulations”). The Regulations will take effect on June 1, 2026.

As the core regulatory instrument governing the registration and administration of overseas manufacturers of imported food, the Regulations apply to all overseas enterprises engaged in the production, processing, or storage of food exported to China. Their issuance aims to implement China’s “four strictest” food safety requirements and further strengthen end-to-end supervision across the imported food supply chain.

For international manufacturers, importers, and brand owners, GACC Order No. 280 introduces higher compliance expectations alongside procedural facilitation mechanisms.

At a Glance: What GACC Order No. 280 Means for Overseas Food Manufacturers

The Regulations establish a more structured, risk-based compliance regime. For overseas enterprises, the following points are most significant:

• Scope: The Regulations apply to all overseas food manufacturers and cover registration, changes, renewal, and post-registration supervision
• Automatic Renewal Mechanism: Registrations remain valid for five years and will be automatically renewed upon expiry for eligible enterprises, unless an exclusion scenario applies
• Dynamic Catalogue Management: The former fixed list of 18 food categories subject to official recommendation has been replaced by a dynamic Catalogue-based system, allowing GACC to adjust registration requirements in response to changing food safety risk profiles
• Timeline: Promulgated on October 14, 2025 and effective from June 1, 2026, with a transition period through May 31, 2026.
• Next Steps: Enterprises should assess exposure early and engage with Cisema to structure compliant registration and renewal strategies.

Why GACC Updated the Overseas Manufacturer Framework

China has experienced sustained growth in imported food volumes, accompanied by an increase in overseas manufacturers and greater diversification of food safety risks. While the existing registration rules implemented in 2022 played an important role in source control, GACC identified the need for further improvements in regulatory precision, process efficiency, and international alignment.

The Regulations represent a systematic upgrade of the existing oversight framework under the dual objectives of “safeguarding the border and promoting development.” Risk management is embedded throughout the registration lifecycle, while balancing regulatory effectiveness with facilitation for enterprises.

GACC Order No. 280 Scope

The Regulations apply to all overseas enterprises that produce, process, or store food exported to China, regardless of whether exports are conducted directly or through intermediaries. Chinese customs will not pass food products manufactured by enterprises that do not hold valid GACC registration. Where registration is revoked, the enterprise loses eligibility to export food to China.

The Regulations govern the full registration lifecycle, including:

• Initial registration approval
• Registration changes and reapplication following material changes
• Registration renewal and automatic extension
• Post-registration supervision, suspension, and revocation

GACC Order No. 280 Implementation Timeline

• October 14, 2025: GACC promulgates GACC Order No. 280
• October 14, 2025–May 31, 2026: Transition period for enterprises to align registrations, update information, and prepare new applications
• June 1, 2026: GACC begins full enforcement; all registrations, changes, and renewals must comply with the new Regulations

Registrations expiring after June 1, 2026, will be automatically renewed for five years, unless an exclusion scenario applies.

Core Regulatory Updates Under GACC Order No. 280

Within this scope and timeline, GACC Order No. 280 introduces a set of interlinked updates that redefine how overseas manufacturers obtain and maintain registration.

1. Enterprise-Led Registration as the Unified Approach

All overseas food manufacturers must submit registration applications in their own name, replacing the former dual-track distinction between authority-recommended and enterprise-applied pathways.

For food categories included in the “Catalogue of Imported Foods Requiring Official Recommendation for Registration” (the “Catalogue”), applications must still be accompanied by:

• A recommendation letter issued by the competent authority of the exporting country or region
• An official inspection report issued or endorsed by that authority

2. Risk-Based Registration Review and Dynamic Catalogue Management

GACC applies a risk management approach when determining registration methods and review intensity, based on:

• The effectiveness of the exporting country or region’s food safety regulatory system
• The inherent food safety risk of the food category concerned

The former fixed list of 18 food categories subject to official recommendation has been adjusted to a Catalogue-based management approach, which GACC may dynamically update in response to changing risk profiles.

3. List-Based Registration for Recognized Regulatory Systems

Where GACC has recognized a foreign food safety regulatory system through bilateral cooperation mechanisms, overseas competent authorities may submit lists of eligible enterprises directly to GACC.

Enterprises included on such lists may be approved through batch registration, in accordance with bilateral arrangements, improving efficiency and reducing administrative burden.

4. Optimized Renewal Procedures and Automatic Renewal

Registration remains valid for five years. Under the Regulations, registrations will be automatically renewed for an additional five years upon expiry, except where enterprises:

• Appear on the “List of Foods Not Eligible for Automatic Renewal”
• Are under rectification or investigation
• Are located in countries or regions subject to GACC food import suspension

To support timely renewal, the Regulations also extend the window for submitting renewal applications from “3 to 6 months before expiry” to “3 to 12 months before expiry,” giving enterprises additional time to prepare.

5. Strengthened Post-Registration Supervision

The Regulations significantly enhance post-registration supervision and enforcement. GACC will:

• Revoke registration where enterprises no longer meet eligibility or registration conditions
• Not accept registration applications from enterprises located in countries or regions subject to food import suspension
• Require overseas manufacturers, overseas competent authorities, and Chinese customs authorities to fulfill defined compliance responsibilities

This establishes a closed-loop, lifecycle regulatory system based on enterprise primary responsibility, effective supervision by overseas competent authorities, and oversight by Chinese customs.

6. Mandatory Baseline Conditions and Regulatory Red Lines

Across all registration pathways, overseas manufacturers must:

• Operate under approval and effective supervision by the competent authority of the exporting country or region
• Maintain food safety and hygiene management systems that comply with Chinese laws and standards
• Meet inspection and quarantine requirements agreed between China and the exporting country or region

GACC may refuse or revoke registration where enterprises:

• Submit false, misleading, or incomplete registration materials
• Fail to continuously meet registration conditions or complete required rectifications
• Submit applications during periods of GACC-imposed import suspension
• Fail to reapply after material changes, such as relocation of production sites or changes in legal representative.

Next Steps for Overseas Food Manufacturers

With the regulatory framework now defined, overseas food manufacturers should use the transition period to focus on actions that directly affect registration eligibility and continuity of market access.

Establish Product Scope and Risk Profile

The first step is to clearly identify which products are exported to China and determine whether they fall within the “Catalogue of Imported Foods Requiring Official Recommendation for Registration.” At the same time, enterprises should assess product risk and the regulatory standing of the exporting country or region, as these factors define the applicable registration method, review intensity, and supporting documentation,

Confirm the Appropriate Registration Route

Once product scope and risk profile are confirmed, enterprises should determine the correct registration pathway. Depending on the product category and country status, registration may proceed through standard enterprise-led application, competent authority recommendation, or list-based submission.

Where recommendation letters or official inspection reports are required, early engagement with the competent authority of the exporting country or region is essential. This ensures alignment on inspection scope, documentation format, and timing, and avoids bottlenecks as the enforcement date approaches.

Prepare Compliance Systems and Registration Materials

Enterprises should then review internal food safety, hygiene, and traceability systems to confirm ongoing compliance with Chinese food safety laws, national standards, and agreed inspection and quarantine requirements. Any gaps should be addressed before submitting registration materials.

Registration documentation should be compiled in an orderly manner, including:

• Acceptable proof of enterprise identity under the Regulations
• Food safety and compliance declarations
• Facility, product, and process information
• Competent authority recommendation letters and inspection or audit reports, where applicable

Completing these steps before May 31, 2026, will reduce the risk of registration delays, rejection, or post-registration corrective actions once full enforcement begins on June 1, 2026.

Key Takeaway

GACC Order No. 280 reflects China’s shift toward a more mature, system-based approach to regulating imported food, replacing static category controls with dynamic, risk-responsive oversight across the registration lifecycle.

With a transition period through May 31, 2026, overseas food manufacturers have a defined opportunity to align registration strategies, competent authority coordination, and internal compliance systems with this framework. Enterprises that act during this window will be better positioned to maintain stable access to the China market once full enforcement begins.

For overseas food manufacturers seeking support in assessing registration exposure and structuring compliant strategies under GACC Order No. 280., get in touch with Cisema today.

References

Read the official regulation issued by the General Administration of Customs of China (Simplified Chinese)