China GACC Overseas Manufacturers Registration

Since January 1, 2022, the General Administration of Customs of China (GACC) has enforced Decree 248, titled the Provisions on the Administration of Registration of Overseas Manufacturers of Imported Foods. This regulation mandates that all overseas enterprises involved in the production, processing, and storage of food products exported to China must complete a formal registration process with the GACC.

The primary objective of this decree is to enhance the traceability of imported food and ensure that overseas facilities maintain safety standards equivalent to China's domestic requirements. Upon successful approval, a unique In-China Registration Number is issued, which must be clearly displayed on both the inner and outer packaging of the products. Registrations granted under this framework are typically valid for a period of five years.

Registration Methods and Scope of Food Categories

The GACC classifies food products into two distinct registration streams based on their risk level. Understanding which category your product falls into is the first critical step for compliance.

Authority-Recommended Registration

This method applies to 18 high-risk food categories. For these products, the manufacturer cannot apply directly; instead, the competent authority in the manufacturer's home country must conduct an audit and formally recommend the facility to the GACC.

• Scope

Includes meat and meat products, aquatic products, dairy, bird's nest products, honey products, eggs and egg products, edible oils and oilseeds, stuffed pasta, edible grains, milled grain industry products, malt, fresh and dehydrated vegetables, dried beans, condiments, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, special dietary foods, and health foods.

• Procedure

The local authority audits the facility, confirms compliance with Chinese standards, and submits the recommendation to GACC for final review.

Self-Application Registration

For all food categories not listed in the high-risk group (such as most processed snacks, beverages, and general prepackaged foods), manufacturers may handle the process independently or through a designated agent.

• Scope

Applies to all other food categories not mentioned above.

• Procedure

The manufacturer or their agent submits a direct registration application through the GACC's online single-window system.

Required Documentation for Registration

To secure a registration number, facilities must provide a comprehensive set of documents that verify their operational legitimacy and safety protocols:

• Manufacturer Basic Information: Business licenses and legal representative details.
• Production License: Issued by the competent authority in the country or region of origin.
• Product Information: Detailed lists and photos of the food products intended for export to China.
• Processing Flowcharts: Technical diagrams illustrating production and storage techniques.
• Compliance Declaration: A formal statement from the manufacturer confirming adherence to Decree 248 and relevant Chinese GB standards.
• Audit Reports: For authority-recommended products, an inspection report from the local regulator is mandatory.

Maintenance and Renewal of GACC Registration

A GACC registration is not a one-time formality but requires ongoing management to remain valid for market access:

• Modifications: Any significant changes, such as production location, legal representative, or facility renovations, require a formal change request or a re-application.
• Extension/Renewal: Applications for extension must be submitted 3 to 6 months prior to the expiry of the current five-year term. Failure to renew in time will result in the invalidation of the registration number.
• Cancellation Risks: Registrations may be canceled if the facility fails to comply with mandatory safety requirements, closes its operations, or fails to apply for timely extensions.

Proregulations' GACC Registration Services

• One-Stop Self-Application Registration Service
  Managing the entire registration process for low-risk food categories, from document preparation to submission and following up with the GACC to secure approval.
• Authority-Recommended Registration Support
  Assisting manufacturers in preparing the specialized documentation required for high-risk categories and coordinating with local competent authorities to facilitate the recommendation process.
• Formula and Label Compliance Review
  Pre-screening product ingredients and label designs against Chinese National Standards (GB standards) to ensure that the physical product matches the registration data.
• GACC System Filing and Account Management
  Setting up and maintaining the manufacturer's account in the GACC single-window system, ensuring all data is accurate and up-to-date.
• Technical Audit and Gap Analysis
  Conducting mock audits of production facilities to identify potential non-compliance issues before the formal submission or local authority inspection.
• Translation and Document Localization
  Providing professional Chinese translation for all registration materials, ensuring technical terms are used correctly to avoid delays in GACC's review.

If you need to ensure your production facility is fully compliant with GACC Decree 248 or require assistance with the "In-China Registration Number" application, please contact us.