China Revises Food Facility Registration Requirements

The Chinese General Administration of Customs (GAC) has published the revised Regulation on Registration and Administration of Overseas Manufacturers of Imported Food (GAC Decree No. 280) [1], which will become effective on June 1, 2026. This new regulation will replace the current food facility registration requirement for foreign companies stipulated in GAC Decree No. 248 [2] that has been implemented in China since January 2022. Since the facility registration requirement applies to almost all types of foods exported to China, industry should become familiar with the new rules to minimize any potential business disruption.

Changes to Facility Registration Types

Under the new registration regulation, GAC continues the dynamic risk-based principle to oversee foreign food companies while modifying the existing registration framework by allowing the two types of facility registration applications to be filed by the individual company. According to the existing GAC Decree No. 248, facility registration applications are classified into two types. One is the registration upon the Official Recommendation (e.g., applicable to foods typically known as higher risks, such as dairy and meat) by the food authority in the exporting country where the foreign food company is located, and the second type is the registration upon application filed by the foreign food company directly with China GAC.

However, it should be noted that GAC inherited the existing Official Recommendation by the food authority in the exporting country for prescribed foods with a higher risk. Thus, if a food is considered high risk by GAC, the company should still obtain an official recommendation letter from the food authority in the home country and include such a letter in the company’s facility registration application that it submits to GAC. Previously, an application for food with a higher risk needed to be submitted by the foreign food authority to China GAC; however, this now can be done directly by the company. This is expected to expedite the process. In January 2025, GAC proposed a draft list of prescribed foods considered higher risk [3] that are subject to the Official Recommendation requirement, which encompassed foods such as dairy, meats, nuts and seeds, rice, eggs, and seafoods, etc. [4]

New “Batch Registration” of Food Facility

Another significant change in the new regulation is that GAC created “batch registration” of foreign food facilities if the food safety management system of a foreign country (region) has been recognized by GAC, and one of the following scenarios applies:

a) The foreign country has signed a food import/export cooperation agreement with China GAC;
b) The foreign country has signed an agreement, memorandum, or joint declaration with China, including food safety collaboration; or
c) Other scenarios in which GAC decides to apply batch registration after risk assessment.

Under the batch registration framework, a foreign food authority may submit a collective list of food companies for facility registration. More importantly, such a framework could capture all types of facility registration, no matter whether the food exported involves a higher risk on the GAC list or ordinary foods (e.g., confectionary and beverages), and companies do not have to submit applications on their own. This will require negotiation between China and foreign food authorities to work out the details. Therefore, it is highly recommended for industry to start to approach the authorities in their home countries to initiate a conversation with GAC.  

Other Registration-related Matters

According to GAC, the intent of the revisions was to ease industry’s regulatory burden and promote international trade. Therefore, in addition to the above changes, it also established the automatic renewal mechanism for registered food facilities. Under the new regulation, each registration is valid for five years and can be automatically renewed. Also, GAC is upgrading the CIFER registration platform – Single Window system [5], which will be more user-friendly under the new regulation.

Since there is still time until the implementation of the new registration system in June 2026, companies should start to review the new requirements and closely monitor the developments to prepare for compliance and ensure a smooth transition.

For more insights, please see the interview [6] on food facility registration recently conducted by the Health Products Association – China (HPA-China) [7] and Jenny Xin Li, Counsel for Keller and Heckman's Shanghai Representative office.

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://beijing.customs.gov.cn/customs/302249/2480148/6775328/index.html
[2] https://www.gov.cn/zhengce/2021-03/12/content_5723374.htm
[3] http://shanghai.customs.gov.cn/eportal/ui?pageId=374237&articleKey=6297231&columnId=374221
[4] This list has not been finalized as of December 18, 2025. More details about GAC’s consultation on the revised draft food facility registration in January 2025 can be found at Keller and Heckman’s newsletter: https://www.khlaw.com/insights/china-revise-registration-requirements-foreign-food-facilities
[5] https://app.singlewindow.cn/cas/login?_loginAb=1&service=https%3A%2F%2Fcifer.singlewindow.cn%2Fciferwebserver%2Fj_spring_cas_security_check
[6] https://www.youtube.com/watch?v=kYbI8AEzZjA
[7] www.hpachina.org