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2021-20: China: Dairy, Seafood, Honey and Other Edible Non-prescribed Goods: Update on new registration process for food processing and storage facilities handling product for export to China and product labelling requirements

Date of issue: 26 November 2021

Date of effect: From 1 January 2022

Reference Number: MAA2021-46 (Dairy), MAA2021-26 (Seafood), MAA2021-20 (NPG)

Related: MAA2021-38, 40, 41 & 43 (Dairy), MAA2021-20, 21, 22 & 24 (Seafood), MAA2021-14, 15, 16 & 18 (NPG)

Attention:

  • Industries—Industry bodies – Dairy Australia, Dairy Export Industry Consultative Committee, Infant Nutrition Council and Seafood Export Consultative Committee, Export dairy and seafood establishments, Australian Food and Grocery Council and Australian Honey Bee Industry Council.
  • Exporters
  • Department of Agriculture, Water and the Environment —Central and Regional offices

Purpose

To provide updated information on the registration of food processing and storage facilities handling product for export to China, and product labelling requirements for food products exported to China.

Summary of key points

  • The Department of Agriculture, Water and the Environment is providing update for the registration of food processing and storage facilities handling product for export to China, and product labelling requirements for food products exported to China.
  • New labelling requirements will only apply to products produced on or after 1 January 2022.
  • Registration for Article 9 products has now opened on the General Administration of Customs of China (GACC) Single Window System (Single Window).
  • Information is provided about the ongoing registration process for facilities producing Article 7 products.

Information about ‘China’s new requirements for imported food’ is published at haveyoursay.awe.
gov.au/food-to-china. This includes frequently asked questions and a recording of the department led webinar held on 22 October 2021 and 25 November 2021.

China has published an English translation of the Registration and Administration of Overseas Producers of Imported Food (Decree 248), which is available at jckspj.customs.gov.cn/spj/zcfg18/
bmgz91/3979122/index.html. China has not published an English translation of the Measures for the Administration of Imported and Exported Food Safety of the People’s Republic of China (Decree 249).

Labelling requirements

The department has received informal advice that General Administration of Customs of the People's Republic of China (GACC) will enforce new labelling requirements for foods exported to China for products produced on or after 1 January 2022. The department is seeking official confirmation from GACC. Please see Section 2.4 and 3.1 below for further information. This advice replaces previous labelling information provided in MAA2021-43 (Dairy), MAA2021-24 (Seafood), MAA2021-18 (NPG).

1 Food processing and storage facilities handling only meat, dairy, and seafood products for export to China

No additional updates for food processing and storage facilities covered under this section. Refer to previous Market Access Advice MAA2021-40 (Dairy), MAA2021-21 (Seafood), MAA2021-15 (NPG)  on this matter for the latest information.

Please refer to Section 4 for information regarding new applications for food processing and storage facilities handling meat, dairy and seafood products for export to China.

2 Food processing and storage facilities handling products for export to China that require department recommendation for registration with China (Article 7 foods)

2.1 Submission of department recommendations for registration with GACC

The department assessed and collated information provided in applications through the online service described in MAA2021-40 (Dairy), MAA2021-21 (Seafood), MAA2021-15 (NPG). Using this information, the department submitted recommendations for registration for food processing and facilities with a history of trade to China to GACC on 29 October 2021. Applications received after 5:00pm AEDT on this day were not included in the submission and may encounter delays with registration.

The department understands GACC will use this information to publish approved lists of food processing and storage facilities on their website. A specific timeframe on when this will occur has not yet been advised.

Please refer to Section 4 for information regarding applications for food processing and storage facilities, with a history of trade to China, which did not apply to the department for recommendation for registration with GACC by the October deadline or are new to exporting to China.

2.2 Amendments to applications already submitted to the department

Facilities which submitted an application to the department through the online service outlined in Section 2.1 and wish to make amendments to this application, are advised to await further advice from the department on how this process will occur.

2.3 Competent authority registration number - allocation of department issued establishment numbers

China’s new requirements for imported food refer to a competent authority issued registration number – this is your departmental establishment number (also referred to as an ER number).

If your facility already has an existing departmental establishment number, this number will continue to be used, and has been provided to China for all food categories your facility handles for export to China which require departmental recommendation for registration.

If your facility does not have an existing departmental establishment number, the department is in the process of allocating new establishment numbers. You will be notified by email of your facility’s establishment number. If a business has multiple facilities, a unique number will be issued for each facility location. This number has been provided to China for all food categories your facility handles for export to China which require departmental recommendation for registration.

2.4 Labelling requirements

The department understands that GACC intends to enforce the following labelling requirements for food products produced on or after 1 January 2022.However, the department is in the process of formally confirming this.

All registered facilities of exported food products must include on the inner (smallest sale unit) and outer (transport packaging) label either the:

  • Competent authority issued registration number, or;
  • GACC issued registration number.

The department has not received official guidance from GACC on whether the storage facility registration number also needs be displayed on exported food product labels. In addition, the department has not received clarity on the format/how the registration number should appear on product labels.

For those food processing facilities that have been issued a departmental establishment number, the department recommends using this number as the ‘competent authority issued registration number’. The department encourages facilities to consider starting to apply this number to labels as soon as they are able to, to avoid any potential clearance delays after 1 January 2022. Information on how this establishment number is issued by the department is available in Section 2.3.

The registration number can be affixed using a stick-on/adhesive label for all food products with the exception of foods for special dietary uses and health foods. Foods for special dietary uses and health foods must have the registration number printed on the smallest sales package and not affixed using a stick-on/adhesive label.

3 Food processing and storage facilities handling product for export to China that require self-registration with GACC (Article 9 foods)

Food processing and storage facilities which handle products for export to China that are not covered under Section 1 and Section 2 must complete self-registration of their facilities through the GACC Single Window System (Single Window).

Facilities are reminded that the Single Window is now available. GACC has released a guidance document that describes the overseas food facility registration process. This is available in Chinese only on the GACC website at: online.customs.gov.cn/static/pages/treeGuide.html.

The department is currently reviewing this information. However, has noted the guidance outlines GACC’s process for issuing a specific GACC registration number to food facilities that apply through the Single Window. The department recommends facilities register through the Single Window as soon as possible before 1 January 2022.

Registration is based on the physical location of the facility. Each location needs to be registered separately. Brand owners using contract manufacturers should not register but ensure each contract manufacturer completes the self-registration process. Contract manufacturers only need to self-register once. Freight forwarders providing transitory storage services do not need to apply.

Attachment 1 provides updated instructions on how to access the Single Window and guidance for starting an application.

Please note: The Single Window is owned and administered by GACC and the department does not have oversight of the information submitted. The guidance is current to the version of the Single Window System available as at 26 November 2021 and may change if GACC provides further information or the Single Window is modified. Food processing and storage facilities that commenced self-registration prior to 1 November 2021, are advised to complete their applications as per advice in Attachment 1.

The department understands the Single Window requires applicants to provide a ‘registration number approved by the competent authority of located country or region’. For those food processing and storage facilities that have already been issued a departmental establishment number, the department recommends using this number when completing the application form. If your facility does not have this, the department recommends the use of either the state/territory/local government issued registration/notification number or another unique identifying number for your business, for example, your Australian Business Number (ABN) or Australian Company Number (ACN). The department recommends that facilities start applying numbers to labels as soon as possible.

The department is also aware that applicants are required to upload a ‘production license certificate issued by the competent authority of the located country’ before submission of the application. Where food processing and storage facilities do have a department issued export registration certificate or export accredited facility certificate, it is recommended to use this. However, for those facilities that do not have this, the department recommends facilities upload a food facility registration certificate issued by a state/territory or local government authority, certificate of free sale or business licence to meet this documentation requirement.

The department warns facilities that are self-registering through the Single Window to be aware of fraudulent websites that are charging excessive fees to assist with registration. GACC do not charge for the registration through the Single Window.

3.1 Labelling requirements

The department understands that GACC intends to enforce the following labelling requirements for food products produced on or after 1 January 2022.However, the department is in the process of formally confirming this.

All registered facilities of exported food products must include on the inner (sale unit containing the pre-packaged food of the individually saleable independent packaging) and outer (transport packaging) label either the:

  • Competent authority issued registration number, or;
  • GACC issued registration number.

If using the ‘registration number approved by the competent authority of located country or region’ it must match the registration number that was used when completing the self-registration process in the Single Window (refer Section 3). That is either your departmental establishment number, your state/territory/local government issued registration/notification number or another unique identifying number for your business, for example, your Australian Business Number (ABN) or Australian Company Number (ACN).

The department has not received official guidance from GACC on whether the storage facility registration number also needs be displayed on exported food product labels. In addition, the department also has not received clarity on the format/how the registration number should appear on product labels.

The registration number can be affixed using a stick-on/adhesive label for all Article 9 food products.

4 New applications for food processing and storage facilities

GACC has recently released guidance on the ongoing application process for Article 7 products. The guidance is only available in Chinese on the GACC website.

Food processing and storage facilities with a history of trade to China that did not apply to the department by the October deadline and those wanting to start exporting to China will need to follow this process. The department is currently translating the documents and will issue an updated Market Access Advice outlining the submission process once this is available.

Attachment 1

  • Registration information for China International Trade Single Window System PDF [725 KB]
  • Registration information for China International Trade Single Window System DOCX [1.4M B]

If you have difficulty accessing these files, please visit web accessibility for assistance.

Further information

Contact exportlisting@aff.gov.au if you have any queries.

The information provided in this advice is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive. The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice. Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.

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Page last updated: 26 November 2021

We acknowledge the continuous connection of First Nations Traditional Owners and Custodians to the lands, seas and waters of Australia. We recognise their care for and cultivation of Country. We pay respect to Elders past and present, and recognise their knowledge and contribution to the productivity, innovation and sustainability of Australia’s agriculture, fisheries and forestry industries.

Artwork: Protecting our Country, Growing our Future
© Amy Allerton, contemporary Aboriginal Artist of the Gumbaynggirr, Bundjalung and Gamilaroi nations.

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