China (People's Republic of) – Export requirements for milk and dairy products

On this page

• 1. Eligible/ineligible product
• 2. Pre-export approvals by the competent authority of the importing country
• 3. Product specifications
• 4. Production controls and inspection requirements
• 5. Packaging, labelling and marking requirements
• 6. Documentation requirements
• 7. Other information

1. Eligible/ineligible product

Milk and dairy products according to the list of codes of the category 17. Dairy, which is on the CIFER platform. It is the responsibility of the exporter to ensure that the products being exported will be covered by the certificate(s) issued by the Canadian Food Inspection Agency (CFIA).

Eligible

• Infant and young children - formula milk products
• Infant and young children formula milk products
• Infant and young children liquid milk formula
• Pasteurized milk and other dairy products
• Raw milk
• Pasteurized milk
• Sterilized milk
• Modulated milk
• Fermented milk
• Milk powder
• Cream, cream and anhydrous cream
• Condensed milk
• Cheese and processed cheese
• Whey powder and whey protein powder
• Other milk and dairy products

Ineligible

• Information not available

2. Pre-export approvals by the competent authority of the importing country

Establishments

China Decrees 248 and 249

• As of January 1, 2022, food establishments that manufacture, process or store foods (cold or dry storages) must be registered with China's General Administration of Customs China (GACC) prior to export to China
• Certain types of foods have been classified by GACC as "high risk" or "medium risk". All other foods are considered by GACC to be "low risk". Milk and dairy products are classified by GACC as "high risk" foods
• Establishments wishing to be on GACC's eligibility list in the China Import Food Enterprise Registration (CIFER) system must be licensed under and in compliance with all aspects of the Safe Food for Canadians Regulations (SFCR), as well as meet China's regulatory requirements. All food establishments, including cold and dry storage warehouses, are also subject to Preventive Control Plan (PCP) requirements under the SFCR
• CFIA advises that food establishments may be subject to audits by GACC at any time. CFIA anticipates that the objective of GACC auditors will be to verify compliance with China's regulatory requirements

CIFER profiles (also called accounts)

• To be eligible to export milk and dairy products to China for human consumption, all dairy establishments must:
  • have a profile (also called an account) in the CIFER online system operated by GACC
  • have their profile in CIFER "certified" by CFIA in order to be able to submit an application for registration
  • be individually approved by GACC, including the registration of their products, in CIFER

Registration and other processes in CIFER

• All applications for registration, modification, cancellation, and renewal must be submitted in CIFER by the establishment to the CFIA for review
  • The CFIA will forward the request to GACC for final approval when the CFIA's review of the application is complete or will return the application to the establishment for amendments, as required
  • GACC conducts its own reviews and approvals of applications after CFIA submission; the timelines for GACC's review and approval processes are not known
• When an establishment that is already approved undergoes a name change, the documentation and labelling must identify the previous legal name, as recorded on the list in CIFER, until such time as the list is officially amended

Note: CFIA is unable to implement any changes to the CIFER system or processes as it is developed and maintained by GACC.

Verifying establishment registration in CIFER

• A list of all GACC registered establishments can be found in the CIFER query system.
• Export of the dairy products to China can start once the establishment is on the GACC list.
• Establishment registrations in CIFER are only valid for a period of 5 years.
  • Establishments must be aware of the expiry date for their registration and apply to renew their registration 3 to 6 months in advance of expiry in order to minimize the risk of trade disruptions.

Products

• All products produced, manufactured, processed, or stored by establishments prior to export to China must be added to establishment profile/account in CIFER
• Once establishments add their food products to their profile/account they must submit a complete application package in CIFER for CFIA review and GACC approval
  • GACC approval leads to registration of the requested additional products in CIFER
• Milk and dairy products requiring approval by China must appear on the list administered by the GACC (Chinese only)
• Exporters are advised to contact their importer to determine if products require approval by GACC
• If products require prior approval, contact your CFIA area office if assistance is required to determine if they are listed

Note: For products that do not require other approvals apart from CIFER, (for example, ice cream) the manufacturer does not need to be on the list of the establishments.

3. Product specifications

• Dairy product specifications are described in detail within Chinese national Guobiao (GB) standards
• The following table lists dairy-related standards that any company seeking to export to China should examine in depth to ensure that their products are in compliance
• It is the responsibility of the manufacturer in collaboration with the Chinese importer to verify the accuracy of this list

4. Production controls and inspection requirements

The inspector must verify during a preventive control inspection that the manufacturer is aware of the standards and requirements of China and has a specific export procedure in place. This procedure must contains the following elements in particular:

• reference to the relevant Chinese regulations and precise the Chinese standards applicable to the exported products (see 3 above)
• how the manufacturer follows changes in Chinese legislation
• comparison of China's regulations/standards/parameters with those of Canada
• the procedure to be followed in the event of a difference between the regulations/standards/parameters of China and those of Canada in order to ensure that the product meets the requirements of China
• the corrective and preventive actions to be considered in the event of non-compliance

Note: To obtain an export certificate, the manufacturer must provide a letter (on a company letterhead and signed by an authorized person of the establishment) stating that they are aware of China's standards and requirements and that a specific export procedure to the product that will be exported to Chine was developed. This letter must accompany the export certificate request for dairy products. The letter template below: Manufacturer's Declaration for Export to the People's Republic of China, RDIMS 8144135, can be used. CFIA will keep this letter on file.

Manufacturer's declaration

• All export requests for milk and dairy products must be accompanied by a Manufacturer's declaration completed and signed by an authorized person of the food manufacturing establishment/facility.
• To request a template of the manufacturer's declaration, please contact your local CFIA office.
• The product(s) must be clearly identified on the manufacturer's declaration and match exactly the product(s) that are part of the export shipment.

Note: Inspectors will verify that the manufacturer's declaration is completed appropriately and reserve the right to request any other information that they think is necessary for the final certification of the product.

Traceability

The manufacturer must develop and implement control programs to demonstrate that products produced for the Chinese market meet applicable requirements and to assure complete segregation when both eligible and ineligible products are present on the premises.

Certification requirements

Health certificates issued by the CFIA contain animal health and public requirements.

Imported dairy ingredients

The use of imported dairy ingredients from certain countries may limit the ability to export to China. The exporter must provide Canadian Food Inspection Agency (CFIA) with all relevant documentation (official documentation from the competent authorities) for the imported dairy ingredients. Any supporting document must be in one of the two official languages of Canada.

5. Packaging, labelling and marking requirements

It is the exporter's responsibility to meet all the requirements for labelling, packaging and marking requirements as required by the importing country.

As of January 1, 2022

• The inner and outer packaging should have strong, clear, and legible Chinese and English or Chinese and export country (region) text marks, indicating the following:
  • name of the product
  • specifications
  • production date
  • lot number
  • shelf life
  • storage conditions
  • the destination must be marked as the People's Republic of China
  • Chinese registration number or the Canadian establishment ID number

Note: the packaging and labelling requirements of foods produced before January 1st, 2022, shall follow the original requirements that were in place prior to the implementation of Decrees 248 and 249.

Establishment Registration Number on packaging

• Milk and dairy products produced on or after January 1, 2022, shall be marked on the inner and outer packaging with China's registration number or the CFIA unique establishment number
• It is the responsibility of exporters to communicate with their importers in China to ensure that the packaging, labelling and marking meet the Chinese import requirements

6. Documentation requirements

Canada has a negotiated certificate with China. Any request to add an additional statement to the certificate must be confirmed by CFIA's Food Import Export Division (FIED).

Certificate

• Health Certificate for the export of dairy and dairy based products for human consumption from Canada to the People's Republic of China TS.CN.
  • This health certificate is normally used for the following Harmonized System (HS) Codes:
    • 0401 – Milk and cream, no sweetening
    • 0402 – Milk and cream with sweetening
    • 0403 – Fermented products
    • 0404 – Whey and whey products
    • 0405 – Butter
    • 0406 – Cheese
    • 1901 – Infant formula
• Health certificate for the export of dairy products and dairy based products for human consumption CFIA/ACIA 5813.
  • This health certificate can be used ice cream. Furthermore, a certificate of origin could be required for these products. The exporter can obtain this document from the Canadian Chamber of Commerce. The CFIA does not need to review this document.

Note:

• The health certificate is signed by the CFIA official veterinarian and official inspector.
• Export certificates cannot be issued for products that have left Canada.

7. Other information

Exported products transiting through a country may require transit documentation. It is the responsibility of the exporter to ensure that the shipment will be accompanied by all necessary certificates.

Samples (personal or commercial) may be subject to the same requirements as a regular shipment. It is strongly recommended that the exporter verify these requirements with their importer.

Establishments are encouraged to verify with their importer prior to shipping that they are registered in CIFER for the correct HS and CIQ Codes. Incorrect HS or CIQ codes in CIFER may delay or prevent shipment clearance upon arrival in China.

Relevant links

• General Administrations of Customs of the People's Republic of China (GACC)
• China Import Food Enterprises Registration
• Registration Information of Overseas manufacturers of Imported Food
• CIFER – Guidance for industry
• CIFER – Checklist tool for industry