China Issues New Guidance on Overseas Food Facility Registration Effective June 1, 2026

On March 18, 2026, the General Administration of Customs of China (GAC) released GAC Announcement No. 27 of 2026 (“Announcement”) [1], which provides guidelines for the implementation of a new registration framework for foreign food facilities that involve most of the prepackaged foods exported to China. 

As reported in our CRM – China Revises Food Facility Registration Requirements, GAC’s new Decree 280 concerning Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food [2] introduces a dynamic, risk-based management system regulating overseas food manufacturers, which is set to take effect on June 1, 2026.   

Under the Announcement, GAC released the long-awaited new list of food categories that are subject to official recommendation by the competent authority of the exporting country. Compared with the existing GAC Decree No. 248, “unroasted coffee and cocoa beans” no longer appear on the list, and other categories – such as oilseeds, dried beans, and seasonings – are narrowed in their scope. On the other hand, some food categories, such as health foods and special dietary foods, which were initially not subject to official recommendation, are now on the final list. 

Further, while Decree 280 introduces automatic five-year renewals for registered facilities, the Announcement specifies a list of food categories subject to non-automatic renewal of registration, which includes meat and meat products, as well as bird’s nest and their products. Moving forward, this list will undergo dynamic adjustment. The scope of storage facilities requiring registration is also clarified in the Announcement, covering terrestrial animal-derived foods and aquatic products, given the high risks associated with their low-temperature transport processes. Thus, not all food storage facilities need to be registered with GAC. 

In addition to the above Announcement, GAC has also recently proposed revisions to the existing notification system for food importers/exporters [3] to align with the evolving trade dynamics and strengthen food safety oversight. Compared with the current practice, the revisions introduce several key updates grounded in the principles of streamlined procedures, unified standards, shortened processing timelines, and end-to-end supply chain supervision. For instance, the customs processing timeframe for food importer notification will be reduced from the current five working days to three working days. The shortened filing timeline reduces administrative lead times, enabling faster market entry and greater operational efficiency. Also, the proposed revisions will establish an exit mechanism for food importers/exporters, signaling a shift toward more rigorous post-market oversight. 

With the upcoming implementation of the new food facility registration system set for June 2026, and newly proposed revisions for notification of food importers/exporters, industry should consider impact on business and engage with partners in and outside China to prepare for compliance to ensure a smooth transition.

If you have any questions or need any assistance with food facility registration or other general food law matters, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), or your existing contact at Keller and Heckman LLP.

Keller and Heckman represents the food industry on regulatory matters in China and across the Asia-Pacific region, including food import/export, labeling, composition review, as well as product applications, etc. Please sign up for our newsletters here.

[1] http://www.customs.gov.cn/customs/2026-03/18/article_2026031809353159843.html  
[2] http://gdfs.customs.gov.cn/customs/302249/2480148/6775328/index.html 
[3] http://www.customs.gov.cn/customs/2026-03/19/article_2026031911450131967.html