Exporting fish products to China

The Department of Agriculture is responsible for the export registration and ensuring ongoing compliance of fish export establishments, exporters and permit issuers with:

Export legislation has been developed to ensure, where possible, that the requirements of importing countries are met.  However, some countries like China have additional requirements that need to be met before you can export your product to that country.  These requirements are specific to individual countries and may include:

  • establishment listing
  • additional microbiological, chemical or physical testing
  • foreign language labeling requirements, or
  • product specific applications.

We are responsible for certifying fish products for export to assure our trading partners that the goods comply with strict export requirements and any additional importing country requirements.

Before you export fish products to China:

Sending processed fish products (not live)

Prescribed fish products to China are only eligible for export if they:

China also requires additional registrations with their government. The General Administration of Customs, People’s Republic of China (GACC) have separate divisions responsible for oversight of the import of live and of non-viable seafood products.

Exporters and manufacturers must register their company details through the Chinese government’s e-platform. This is an administrative process which you can complete yourself.

Export registered establishments

GACCs Food Safety Bureau (FSB) maintains a list of registered seafood establishments approved to export non-viable seafood products to China. The list of approved establishments is available at: GACC Australian approved establishment list.

Prior to export, establishments are advised to confirm their establishment details that appear on export certification for their consignments match the establishment details on GACCs published list. Exporting product on certification that does not match could result in detainment of consignments.

Establishments applying for:

  • a new listing, manufacturers and storage establishments of non-viable fish products (frozen, chilled, not live) must complete a new listing application
  • an amendment (e.g. change in name or address) you must complete an amendment application.

All applications should be submitted to dairyeggsfish@agriculture.gov.au for assessment and verification. Applications will be submitted on a quarterly basis in March, June, September and December. Cut off times for the lodgment of application documents are 15th February, 15th May, 15th August and 15th November. Incomplete or inaccurate applications will be returned for amendment and a fee for service charge will be applied.

We cannot confirm the timeframe for GACC to update the completed list following our quarterly submissions. We utilises every opportunity we have to progress Australia’s applications and listings requests, though the timing of listing is generally outside of the departments control.

Establishments are required to complete the following application forms as applicable:

Download

DocumentPagesFile size
New Listing Application - Seafood Processing Establishment DOC569 KB
New Listing Application - Seafood Storage Establishment DOC463 KB
Listing Amendment Application - Seafood Processing Establishment DOC572 KB
Listing Amendment Application - Seafood Storage Establishment DOC467 KB

If you have difficulty accessing this file, visit web accessibility for assistance.

Guidelines are available to assist with the completion of the application:

DocumentPagesFile size
Application Guide – Seafood Processing Establishment DOC3106 KB
Application Guide – Seafood Storage Establishment DOC296 KB

If you have difficulty accessing this file, visit web accessibility for assistance.

Seafood products exempt from the non-viable eligible species list

We have been advised that the (non-viable) eligible species list is not applicable to products whose Harmonised System (HS) tariff codes are located in 1603000090-1605909090 or 2103909000:

  • 1603 – Extracts and juices of meat, fish or crustaceans, molluscs or other aquatic invertebrates
  • 1604 – Prepared or preserved fish (whole or in pieces, but not minced) and caviar and caviar substitutes prepared from fish eggs
  • 1605 – Crustaceans, molluscs and other aquatic invertebrates, prepared or preserved
  • 21039090 – Sauces and preparations therefor, containing more than 20% by weight, fish crustaceans, molluscs or other aquatic invertebrates.

You can investigate whether your seafood products may be legitimately tariffed under the above Harmonised System Codes and exported to China without needing to be on the non-viable eligible species list.

If you are unsure of the Tariff code being applied to your product you should contact your importer or customs broker for further information.

Sending live fish products

Prescribed fish products to China are only eligible for export if they:

China also requires additional registrations with their government. The General Administration of Customs, People’s Republic of China (GACC) have separate divisions responsible for oversight of the import of live and of non-viable seafood products.

Exporters and manufacturers must register their company details through the Chinese government’s e-platform. This is an administrative process which you can complete yourself.

Export registered establishments

GACCs Animal and Plant Quarantine Division (APQ) requires a list of registered seafood establishments approved to export live seafood products to China.

In August 2019 the department provided GACC APQ with an updated list of live establishments. APQ has acknowledged receipt of the list but has not yet advised if the list meets their requirements or if the list will be made publically available. We will continue to follow up and provide industry with updated information as it becomes available.

Export establishments who have not previously exported live seafood products to China should:

  • note that exports will be at their commercial risk until the department is able to confirm that GACC APQ has accepted our listing submission
  • work closely with their importers and consider sending small shipments initially to confirm their approval to export and successful clearance of consignments
  • notify us immediately should they experience difficulties with clearance of consignments.

Sending fish products without certification

Some consignments of fish products do not require certification from us before you send them to China:

  • Consignments where the goods are legally imported into Australia and have not been further processed or repacked before being re-exported. Goods in this category can be exported in any quantity without further involvement from us. You should consult with your overseas buyer or consignee to make sure there are no other documentation requirements you must meet to clear your goods in China.
    • Imported product will have the country of origin on the label and carton.
  • Consignments less than 10 kg. Generally export legislation does not apply to consignments of less than 10 kg. You can purchase Australian made fish products from the supermarket or outside the export chain and then send them to China as long as your shipment is less than 10 kg.
    • Product manufactured in Australia will be identified as ‘Made in Australia’, ‘Packed in Australia’ or ‘Product of Australia’.

Be aware that a number of changes to China’s ecommerce legislation were implemented in 2017. These changes will affect the export of small consignments or shipments outside the normal export channel, such as internet sales and shipments into the Free Trade Zone. Your buyer is best positioned to advise of eligibility into China’s Free Trade Zone.

What is a consignment?

The term consignment means the specific lot of goods being sent to a single consignee in the destination country at a particular time.

For example; if you are arranging a shipment of 100 x 8kg cartons of Australian made product and each 8 kg carton is clearly identified as being consigned to a different consignee/customer, then the shipment would satisfy the requirement for ‘less than 10 kg per consignment’ and no export requirements apply (if accepted by the importing country).

To meet the ‘less than 10 kg per consignment’ criteria, each consignment within the shipment must be clearly:

  • distinguishable as containing less than 10 kg of prescribed fish or fish products
  • consigned to different consignees.

If the 100 x 8 kg cartons were consigned to just one consignee/customer, the export legislation will apply and an export permit is required.

If a freight forwarder is approached to export fish products that are not covered by an export permit, or have been incorrectly declared, or greater than 10kg and not eligible for export then they should contact us at dairyeggsfish@agriculture.gov.au.