Exporting dairy products to China
The Department of Agriculture, Water and the Environment is responsible for the export registration and ensuring ongoing compliance of dairy export establishments, exporters and permit issuers with:
- Export Control Act 1982 and associated legislation
- applicable importing country requirements.
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 dairy 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 dairy products to China:
- read this overview for guidance on requirements and exceptions
- check our Manual for Importing Country Requirements (Micor) for full details of China’s dairy import requirements.
- details of the exporting process can be found in our step by step guide to exporting dairy products.
Sending processed dairy products
Prescribed dairy products to China are only eligible for export if they:
- are sourced from and/or manufactured by an export registered establishment who is also listed with China to manufacture the specific type of dairy products
- remain within export registered establishments (including storage facilities) until they are exported – this is the export supply chain
- are exported by an individual or company registered with us as an exporter.
Non-bovine milk products (such as sheep and goat milk) need to meet the same registration and export requirements as bovine (cow) milk products when exported to China.
China also requires additional approvals and registrations with their government. The General Administration of Customs, People’s Republic of China (GACC) is responsible for approving and publishing their list of Australian dairy establishments.
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
GACC maintains a list of registered dairy establishments approved to export dairy products to China. The list of approved establishments is available on the GACC website.
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.
The department submits a list of establishments who are export registered to manufacture dairy products. The lists are submitted on a quarterly basis in March, June, September and December for China to review and publish the approved establishments on their website.
Some products require additional information to be submitted to GACC before they will be included on this listing (see product specific headings below).
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.
Sending pasteurised liquid milk and fermented milk products
Prior to approval and listing with GACC, manufacturers of fermented milk (yoghurt products), pasteurised liquid milk (fresh milk and sterilised (UHT) milk products) and modified milk must meet additional requirements.
Before you can export these types of products to China you must submit an application to the department. Submissions must also include relevant supporting information outlining your company’s compliance with requirements. Supporting information may include:
- shelf life validation
- cold chain compliance
- procedures supporting product testing to Chinese standards
- procedures supporting product safety
- HACCP; and
- if applicable, evidence of additional registrations, certification and/or approvals such as organic, Halal or Kosher certifications.
All applications should be submitted to firstname.lastname@example.org for assessment and verification prior to submission to GACC. You will be charged a fee for service charge for any assessment and or follow up review of your application. Fees and charges are outlined in the departments charging guidelines.
We cannot confirm the timeframe for GACC to approve these applications or to update listings, historically there have been significant delays. 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.
Sending infant formula products
Before exporting infant formula to China, you will need to meet all of China’s Registration requirements:
Infant formula being exported to China must be:
- sourced from a manufacturer listed on the GACC website. These establishments have been audited, approved and listed by GACC.
- a brand specific that has been approved and listed by China’s State Administration of Market Regulation (SAMR).
- clearly marked with an expiry date more than three months from the time the product arrives in China.
- labelled in Chinese which should be printed on the retail package.
Export registered establishments
To be listed by GACC as an approved infant formula manufacturer your establishment may be audited by China to ensure Chinese legislative requirements have been met. China classifies infant formula as all stage 1, 2 and 3 products.
To be considered for listing by GACC manufacturing companies must:
- undertake a blending process where all major and minor ingredients are blended together prior to canning. Companies who only can or pack infant formula without blending will not be approved.
- package infant formula in retail packages. China will not accept bulk infant formula products.
To apply for registration you must complete China’s registration application form which has two parts:
- General information about the company
This part includes information about:
- Production – including procedures detailing HACCP and cleaning including automated clean in place processes (CIP)
- raw materials
- product identity, traceability and recall
- product testing
- the location and environment of your manufacturing establishment; and
- procedures on good manufacturing practices for powder formulas for infants and young children.
- Overview of the company’s exports to China
This part includes information about:
- relationships between the producer, exporter, importer, trademark holder that exports the products to China and the responsible party that exports the products to China.
- details about procedures in China including importer information, trademarks, consumer complaints system and recall processes.
All applications should be submitted to email@example.com for assessment and verification. Incomplete or inaccurate applications will be returned for amendment. You will be charged a fee for service for any assessment and any follow-up review of your application. Fees and charges are outlined in the departments charging guidelines.
Once approved and listed by GACC as an infant formula manufacturer, your product brands must also be approved by China’s State Administration of Market Regulation (SAMR). SAMR is responsible for food safety, inspections, testing and quality supervision.
Prior to 2019 this process was managed by the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ), and the China Food and Drug Administration (CFDA).
The department has no formal role in the SAMR registration process however we understand that:
- a link to the application forms should be obtained from SAMR. There is a copy on our website, however this may not be the most current version.
- applications must be submitted in Mandarin to SAMR directly in hard copy and a soft copy submitted through the SAMR website.
- SAMR may request an on-site audit at the manufacturing establishment prior to registering infant formula brands. If an audit is requested at your establishment please notify us by emailing firstname.lastname@example.org
Sending dairy products without certification
Some consignments of dairy 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.
- Examples of imported infant formula include Karricare, Aptimal, Aptimal Gold, S26 and A2 infant formula.
- Consignments less than 10 kg. Generally export legislation does not apply to consignments of less than 10 kg. You can purchase Australian made dairy 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 dairy or dairy products
- consigned to different consignees.
If the 100 x 8 kg cartons were consigned to just one consignee/customer, the export legislation and importing country requirements will apply and an export permit is required.
If a freight forwarder is approached to export dairy 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 email@example.com.