Walk-Through Explanation of the GACC Registration Process

07 Marzo 2022

On March 1st, the China-Italy Chamber of Commerce (CICC), together with the EU SME Centre, held the workshop “Update on Customs and Logistics Requirements for Imported F&B Products”, attracting more than 130 attendees both online and offline in Shanghai and Guangzhou.

The workshop, moderated by Vincenzo Morano, Vice Coordinator of the CICC Logistics Working Group, helped to clarify the new regulations of the General Administration of Customs’ Order 248 and 249, which came into force on January 1st 2022, requiring all F&B manufacturers exporting to China to obtain a new registration code and to display it on the product’s package.

During the event, Lennie Tao, Senior Regulatory Analyst at ChemLinked, provided a step-by-step guidance on how to register through the dedicated platform, focusing on aspects that are frequently filled in a wrong manner.

"Now if enterprises of the 18 food categories want to apply for the registration number for new food categories, they can get a system account and password from their local competent authorities. Then log in the registration system to apply for the registration for new products by themselves in the future."

"We suggest that you can fill in the information you know as much as possible. More information can help the GACC official make decisions about your product safety. In your case if you change the supplier very frequently, then you can skip the “raw material” part."

Lennie Tao, Senior Regulatory Analyst at ChemLinked

Who is the ‘competent authority’ in my country that I should approach for help? How does the registration process work?

Our company does not have a regular supplier of raw materials, we change them constantly. How do I fill in the relevant information in the system?

My product is partially made in one country at one location, finished in another country in another location, which enterprise should I register in the manufacturer’s registry database?

These are only a small part of the frequently asked questions received by the EU SME Centre on specific aspects and cases for the registration and presented by Alessio Petino, the Knowledge Coordinator of the EU SME Centre.

Following, Tony Huang, Vice General Manager at Shanghai Free Trade Zones International Logistics Co., LTD shared insights on the practical implementation of GACC 248 and 249 in Shanghai’s Yangshan port.

"Article 1 of Announcement No. 248 is about the legislative purpose and legislative basis of these Provisions. Article 2 is about the scope of application of these regulations. So what is the definition of food in this regulation, and why is this regulation formulated? In fact, food refers to various finished products and raw materials for human consumption or drinking, as well as articles that are traditionally both food and Chinese medicinal materials, but does not include articles for the purpose of treatment."

"The purpose of Decree 248 is to ensure the safety of imported foods, so the manufacturer that is legally liable for the product safety shall complete the registration."

"Transit warehouses where foods are kept in room temperature and also without any processing and packaging activities are exempted from this manufacturer registration."

Tony Huang, Vice General Manager at Shanghai Free Trade Zones International Logistics Co., LTD

The seminar ended with a panel discussion and answers to the participants by two experts of the Food and Beverage and Logistic industry, Ciro Cristiano, Project Manager & Food Specialist at GF Logistic Shanghai, and Owen Chen, South China Manager of Ventana Serra Freight Forwarding (Shanghai) Co., Ltd, who illustrated the logistics requirements as well as recent trends for shipping F&B products from the EU to China.

"Due to the new GACC regulation there is not real impact in the shipment transit and logistics procedures."

"Goods manufactured before January 1st 2022 do not need to show the registration code in the label but need to be registered in the system."

"Do run a pre-checking document with your agent or importer before shipping out your goods to China." "It's important to define the right HScode of your goods before applying for the manufacturer registration."