China: Establishment listing requirements for approval to export viable and non-viable seafood products from Australia (2019-06)

Date of issue:  13 September 2019

Date of effect: Immediate

Reference Number: MAA2019-06


  • Industries— Seafood
  • Export registered seafood establishments
  • Licensed exporters
  • Department of Agriculture—Central and Regional offices


To notify export registered seafood establishments that:

  • China’s General Administration of Customs (GACC) has updated its list of approved Australian seafood export establishments for non-viable seafood products.
  • GACC has implemented additional establishment listing requirements for the export of viable and non-viable seafood products to China.

Summary of key points

GACC has separate divisions responsible for oversight of the import of live and of non-viable seafood products.

There are now different establishment listing requirements for the export of live fish and non-viable fish and fish products, outlined below:

Exporting non-viable (frozen, chilled) seafood to China

GACCs Food Safety Bureau (FSB) maintains a list of registered seafood establishments approved to export non-viable seafood products to China. In early September 2019, GACC updated the list to include all outstanding listing requests. The list of approved establishments is available at: GACC Australian approved establishment list. The published September update is attached for reference (Attachment 1).

The latest listing update confirms FSB’s recent advice that establishments exporting live product only, will no longer be included in updates to the establishment list that they maintain.

FSB have advised that establishments seeking new listing must now provide additional information to support their request for listing. To meet these requirements the department has developed an application listing template for establishments to complete. These applications will be submitted to GACC by the department on a quarterly basis.

These requirement also apply to establishments seeking amendments to an existing listing (for example; where there is a change to company name).

Application forms are attached, can be downloaded from MICoR, or by e-mailing your request to
Establishments are required to complete the following application form as applicable:

DocumentPagesFile size
Attachment 1: Australian seafood establishment PDF47343 KB
Attachment 2: China GACC New Listing Application (Seafood Processing Establishment) DOC556 KB
Attachement 3: China GACC New Listing Application (Seafood Storage Establishment) DOC451 KB
Attachement 4: China GACC Listing Amendment Application(Seafood Processing Establishment) DOC560 KB
Attachement 5: China GACC Listing Amendment Application(Seafood Storage Establishment) DOC554 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
Attachment 6: China GACC Application Guide – Seafood Processing Establishment DOC358 KB
Attachement 7: China GACC Application Guide – Seafood Storage Establishment DOC229 KB

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

Completed applications should be submitted to for assessment and verification. Incomplete or inaccurate applications will be returned for amendment and a fee for service charge will be applied. Verified applications will be submitted directly to GACC by the department.

The department cannot confirm the timeframe for GACC to update the published list following future quarterly submissions.

Prior to export, establishments are advised to confirm the establishment details that appear on export certification for their consignments match the establishment details on the establishment list published on GACC’s website. Exporting product on certification that does not match the published list could result in detainment of consignments. Exporters should notify the department immediately should their consignments be detained.

The department will continue to submit listing updates on a quarterly basis in March, June, September and December. There will be a cut-off time for the lodgement of application documents of 15th February, 15th May, 15th August and 15th November to ensure timely delivery of the quarterly submissions to China. Applications received by the department after these cut-off dates will be held over to the next quarterly submission.

All Exporters are again reminded that non-viable seafood species exported to China must also be eligible under the non-viable eligible species list for Australia. Non-Viable eligible species list - Australia (current April 2019).

Exporting viable (live) seafood to China

The department has recently been advised that GACC’s Animal and Plant Quarantine Division (APQ) requires a list of registered Australian 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 i.e. establishments that have live fish cut codes listed against the establishment. GACC 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. The department will continue to follow up and provide industry with updated information as it becomes available.

All Exporters are also reminded that live seafood species exported to China must also be eligible under the live eligible species list for Australia:

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

  1. Should confirm with the department that their establishment was included on the August 2019 submission, prior to export.
  2. 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.
  3. Should work closely with their importers and consider sending small shipments initially to confirm their approval to export and successful clearance of consignments.
  4. Notify the department immediately should they experience difficulties with clearance of consignments.

Seafood products exempt from the non-viable eligible species list

The department has 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.

Industry can investigate whether their seafood products may be legitimately tariffed under the above Harmonised System Codes and therefore exported to China without the need for non-viable eligible species listing. If you are unsure of the Tariff code being applied to your product you should contact your importer or customs broker for further information.

Please contact the Dairy Egg Fish program at Dairy Eggs Fish for more information or assistance with completion of listing applications.

The Manual of Importing Country Requirements (MICoR) will be updated to reflect the changes.

Further information

Contact 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.

Last reviewed: 4 November 2019
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