Food imports into China: the three approvals that exist before your first shipment

Food is the category where the largest number of otherwise sound shipments turn out to be impossible, and the reason is structural rather than operational. Three separate approvals have to exist before a consignment can be declared at all, they are held by three different parties, and none of them can be obtained while cargo is in transit.

They are worth checking in the order below, because each one is pointless without the one before it.

The first question is whether the country is approved at all

China grants access by country and by product category. Meat, dairy, aquatic products, edible bird’s nest and plant-derived foods all sit under access management, and a country approved for one is not thereby approved for another. Access lists are published by GACC and can be checked before anything else is discussed.

If the origin country is not on the list for that product category, nothing further in this article applies. There is no importer, no licence and no routing that resolves it.

The second is whether the producing facility is registered in China

The overseas manufacturer must hold a Chinese registration number, obtained by one of two routes depending on the product:

• Recommended registration — for seventeen categories including meat products, aquatic products, dairy and edible bird’s nest. The competent authority in the exporting country reviews the facility and recommends it to GACC.
• Self-registration — for other foods, submitted by the facility itself through the overseas facility registration system.

Registrations can be checked on CIFER at ciferquery.singlewindow.cn. Where an application is incomplete, GACC notifies the required corrections in one consolidated response within twenty working days of receipt.

This registration number is not merely background paperwork. It has to be entered in the product qualification field of the declaration, and an entry without it is rejected by the system.

The third is whether the traders are on file

Two filings, in opposite directions:

• The domestic importer files with the customs office where it is established. The filing does not expire.
• The overseas exporter or agent files with GACC and receives an eighteen-digit code.

Both are done online through the Single Window (singlewindow.cn) or the Internet+Customs platform (online.customs.gov.cn).

Where the importer’s filed details change — address, legal representative, contact, business scope, the categories actually traded, the address where food is stored — the change must be filed within thirty days. This is one of the three things customs examines when it audits an importer, and a filing that no longer matches reality is the easiest of the three to fail.

A fourth, for some products: the quarantine permit

Animal-derived foods additionally need a Quarantine Permit for Entry Animals and Plants (《中华人民共和国进境动植物检疫许可证》) obtained before import. It applies to:

• Meat and meat products, including offal and casings — cooked meat products excepted
• Aquatic products, including amphibians, reptiles and aquatic mammals, and other farmed aquatic products — cooked products excepted
• Fresh eggs
• Fresh milk, including pasteurised milk, raw milk and raw milk products
• Edible bird’s nest, including unprocessed nests

The applicant must be an independent legal person that signs the trade contract directly — which is one of the points at which the identity of the importer becomes a design decision rather than an administrative detail. The exporting country and any transit country must be free of relevant animal and plant disease, and the trade must comply with any bilateral quarantine protocol between China and that country.

The declaration itself: three fields that reject entries

Beyond the ordinary commercial documents — contract, invoice, packing list, transport document — and the official certificates (certificate of origin is required for all imported food; phytosanitary, veterinary health and health certificates as applicable), three declaration fields cause avoidable rejections:

1. Product qualification must carry the overseas facility registration number. Missing it returns the entry.
2. Commodity details — name, specification, quantity, price — must agree with the documents.
3. Use must be stated as food use. Anything else and customs will not accept the declaration.

Where a customs broker declares on the importer’s behalf, a signed authorisation is required; where the parties are the same company, it is not.

Inspection, and the fifteen-day clock if you disagree

Assessment runs document review → physical examination of packaging, labelling, quantity → sampling and laboratory testing where an instruction is triggered. A passing consignment is released with an Inspection and Quarantine Certificate for Inbound Goods, and the food may not be sold or used before that certificate is issued.

Where a result is contested, the importer may apply for re-inspection within fifteen days of receiving it, with the goods and their seals kept in their original state. Customs completes its review within fifteen days and issues a re-inspection conclusion within sixty days of accepting the application, extendable by up to thirty days for technically complex cases.

Three situations are not re-inspected at all: results showing microbiological limits exceeded, reserve samples past their shelf life, and any case where the reserve sample can no longer serve the purpose. The first of those is worth reading twice — a microbiological failure has no appeal route, so the sampling stage is where the outcome is effectively decided.

Failures on safety, health or environmental grounds are destroyed or re-exported. Failures on other grounds may be admitted if technical treatment brings them into conformity within the permitted period.

After release, the obligations continue

Importers must keep import records and sales records covering product name, specification, quantity, production date, shelf life, the overseas exporter and the buyer, and the dates of import and sale. Retention is at least six months beyond the end of shelf life, or at least two years where no shelf life is stated.

Customs audits these records against the filing, and requires a recall system to be in place, with any non-conforming food recalled and reported to the local customs office. When an audit happens, copies retained by customs are annotated with their source, page count, date of copying and the words confirming the copy matches the original, and signed.

What this means in planning terms

The useful sequence is: confirm country and category access, confirm the facility’s registration, complete both trader filings, obtain the quarantine permit where the product needs one, and only then plan the shipment. Each step depends on the one before it, and the total lead time is measured in weeks or months, not days.

Where a buyer cannot hold one of these positions itself, that is a question worth raising before a purchase contract is signed rather than after the goods have been produced. It is one of the situations we handle as importer of record.