A key element outlined by the Food Safety Law is that all F&B operators shall be liable for the safety of F&B products that they produce or distribute. On this basis, in April 2021, the General Administration of Customs of the People’s Republic of China (GACC) issued the Administrative Provisions on Registration of Overseas Manufacturers of Imported Foods, which officially came into force on 1 January 2022. The Provisions, commonly referred to as GACC Decree 248, stipulate that all overseas establishments that produce, process, or store any type of F&B product that is exported to China must register through a dedicated platform, obtain a registration code from GACC, and display it on the product’s inner and outer packaging – before the product is exported to China. Together with another GACC regulation which came into force at the same time – GACC Decree 249 – the regulation significantly increases the responsibility and liability of overseas F&B establishments and of the food safety competent authorities in their countries.
However, the ambition to achieve the objectives of GACC Decree 248 has not always been accompanied by adequate awareness-raising efforts to instruct the overseas F&B establishments concerned. Many doubts, uncertainty, and questions on different aspects of the registration process continue to exist even after a few months of enforcement; these are often combined with IT bugs or sudden changes in the registration system which are rarely explained. A frequent outcome is the rejection of applications submitted by overseas F&B establishments, in turn making it temporarily impossible for them to export their products to the Chinese market. Many have reached out to the EU SME Centre seeking assistance with their specific cases.
For this reason, these guidelines were produced to assist European F&B establishments to complete the mandatory GACC registration process.
You will find in these guidelines:
An overview of the key elements of GACC Decree 248 is provided, focusing in particular on the scope of application, different risk levels of F&B categories, packaging requirements, as well as overall significance and impact.
The seven key steps that European F&B establishments must follow to complete the GACC registration process, supported by screenshots taken directly from the system as well as tips on how to avoid mistakes.
The new requirements to display the GACC registration code on the packaging and labelling of different product categories.
A summary of Frequently Asked Questions (FAQs) that the EU SME Centre has received from European F&B establishments, and which were successfully addressed by a team of experts – often after several rounds of calls with GACC operators.
A list of the food safety competent authorities in EU Member States is provided, as close coordination with them will be required for certain F&B product categories.
Overview of GACC Decree 248
Scope of application
Product categories and registration procedures
Other requirements: packaging and labelling
Significance and impact
Step-by-step guide for completing GACC registration
Step 1: Determination of the risk level of the product to be exported
Step 2: Identification of the overseas competent authority for high-risk products
Step 3: Creation of account on CIFER system
Step 4: Completing the registration
Step 5: Application status
Step 6: Approval of the registration
Step 7: Modification, extension or cancellation of the registration
Requirements on packaging and labelling
General rules and standards on packaging and labelling
Additional requirements for specific high-risk product categories
Additional requirements relating to COVID-19
FAQs on GACC registration
Annex: List of food safety competent authorities in EU Member States