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China (People's Republic of) – Export requirements for all other foods and agri-food products

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Eligible/ineligible products

Eligible products

Under decrees 248 and 249, food and agri-food product types have been classified by China's General Administration of Customs China (GACC) as either "high risk", "medium risk", or "low risk".

Note: for information on "high-risk" food products for export to China, please refer to the individual product type web pages for meat and poultry, fish and seafood, and milk and dairy products in the Canadian Food Inspection Agency's (CFIA) Food export requirements library.

Ineligible products

Food or agri-food products for which Canada does not have market access are not eligible for export to China. Such products cannot be registered, that is, cannot be added by establishments to their profiles in the China Import Food Enterprise Registration (CIFER) system.

Currently ineligible "medium risk" products include:

Currently ineligible "low risk" products include most types of fresh fruit and vegetable products for export to China due to plant health restrictions.

For more information, please refer to Documentation requirements (Non-CIFER)

Note: exporters who are interested in exporting currently ineligible products to China may contact Agriculture and Agri-food Canada's (AAFC) Market Access Secretariat (MAS) by email at: aafc.mas-sam.aac@agr.gc.ca.

Pre-export registration requirements

Pre-export registration in the China Import Food Enterprise Registration (CIFER) system

Most "medium-risk" food establishments which manufacture, process or store (for example, cold storage) food and agri-food products prior to export to China must be approved by CFIA prior to submitting their "applications for registration" in the China Import Food Enterprise Registration (CIFER) system.

The "medium risk" food product types requiring registration in CIFER prior to export to China include:

As of 2023, certain "medium-risk" products no longer have to be registered in CIFER. Please refer to Pre-export submission to Market Access Secretariat (MAS) – listing registration with GACC below.

Canadian establishments responsible for "low-risk" products, and their product registrations, are approved directly by GACC in CIFER without CFIA involvement.

Licensing under the Safe Food for Canadians Regulations (SFCR)

"Medium risk" establishments wishing to be approved by GACC in the CIFER system and whose products will be registered in CIFER, must first 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.

Note: companies being registered under GACC's new listing registration process for some medium risk products do not need a SFC licence unless they are required to have one for other reasons unrelated to food exports to China.

All licenced food establishments, including cold storage warehouses, are also subject to preventive control plan (PCP) requirements under the SFCR.

Establishment SFC licences must include the activity "preparing food for export".

Note: SFCR licence expiry – Establishments are advised to renew their existing SFCR licence with the CFIA well in advance of their SFCR licence expiration date. Expiration of an SFCR licence automatically leads to CFIA issuance of a new SFCR licence number after the lapse in SFCR registration. However, a change in an establishment's SFCR licence number could negatively affect their registration status with GACC and subsequent clearance of shipments upon arrival in China.

CFIA application form

The CFIA requires all food and agri-food establishments to complete a CFIA application form prior to applications being submitted in CIFER.

The application form functions as a legal authorization for CFIA to submit establishment information to GACC in the CIFER system and as a legal waiver of CFIA liability for GACC's decisions related to CIFER applications.

The CFIA application form can be obtained from the local CFIA office.

Medium risk establishment identification numbers for registration in CIFER

GACC requires all establishments to have an "overseas registration number" issued by the foreign competent authority of the exporting country; in Canada, CFIA is the competent authority.

All foreign establishments who become registered in the CIFER system will be assigned a lengthy "China registration number" by GACC. Registration numbers issued by GACC to Canadian establishments begin with the designation "CCAN"

"Medium risk" establishments require a CFIA-issued establishment identification number prior to creating a profile/account in CIFER.

The establishment identification number can be either:

Pre-export submission to Market Access Secretariat (MAS) – listing registration with GACC

As of October 28, 2022, "medium-risk" food companies which export, manufacture, process or store certain food and agri-food products prior to export to China must be submitted to Agriculture and Agri-Food Canada's (AAFC) Market Access Secretariat (MAS). Generic company information is regularly submitted to GACC by MAS for listing registration. For the types of "medium risk" products that require listing registration rather than registration in CIFER, please refer to China's decree 248 – lists of high-risk and medium-risk products.

Medium risk company identification numbers for listing registration

Canadian companies which self-identify to MAS their interest in exporting, processing, manufacturing, or storing certain medium risk food products for export to China and require listing by GACC will be assigned an identification number by MAS.

"Low risk" establishment identification numbers

Canadian establishments responsible for "low risk" products do not require a CFIA issued identification number in order to create their profile/account in CIFER.

Note: Establishments should not use their SFC licence number as their "overseas registration number" because the SFC licence number is subject to change in certain circumstances, for example, when a licence expires.

Pre-export registration by competent authority of importing country – CIFER system

CIFER profiles and application processes for medium risk establishments

To be eligible to export food to China for human consumption, all "medium risk" food and agri-food product establishments, including processors, manufacturers, cold storage warehouses, and dry storage warehouses which conduct SFCR licensable activities must:

All establishment applications for new registration, modifications to profile, additions to product list, cancellations, renewals, and legal name changes must be submitted in CIFER by the establishment for CFIA review prior to CFIA submission to GACC for review and approval.

Establishments must upload to CIFER all supporting documents requested by GACC.

When the CFIA's review of the application package is complete, the CFIA will email a copy of GACC's product specific inspection checklist and the CFIA application form to the establishment for completion, signature by the company's legal representative, and applying the company seal or stamp.

Upon receipt of the completed and signed checklist and CFIA application form, the CFIA will review and submit the complete application package in CIFER for GACC review and final approval.

CFIA may send back the application to the establishment for amendments within CIFER, as required.

GACC returns applications to establishments within CIFER when corrections are necessary. Rarely, GACC may directly request CFIA to perform corrections. Where possible, CFIA will try to advise establishments on appropriate changes.

Note: the timelines for GACC reviews and approval processes cannot be estimated by the CFIA. At this time, GACC usually returns establishment application packages multiple times for corrections. It is recommended that after CFIA submission to GACC that establishments monitor their CIFER accounts daily for feedback response from GACC.

CIFER profiles and processes for low risk establishments

To be eligible to export food and agrifood products to China for human consumption, all "low risk" food product establishments, including processors, manufacturers, and cold and dry storage warehouses, must:

At this time, the CFIA is not aware of any additional approvals or processes required by GACC for "low risk" establishments

Note: CFIA is unable to implement any changes to either the structure or functions of the CIFER system or its processes as the system was developed by and is maintained by GACC. Final decisions regarding establishments and product related approvals are at the discretion of GACC.

Verifying establishment registration in CIFER

A list of all GACC registered establishments can be found in the CIFER query system.

"Medium risk" 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.

Verifying listing registration of companies with GACC

Once listed by GACC, Canadian companies may review their related corporate information on the currently approved version of the list through the following links on the GACC-DAPQ public website:

Exemptions

SFCR licence

Some food establishments are exempt from domestic Canadian licensing under the SFCR because of the type of product they produce, process, or manufacture, for example, alcoholic beverages, and foods listed in Schedule 1 of the SFCR that are not processed and will be manufactured, processed, or treated for use as grain, oil, pulse, sugar or beverages.

However, if a Canadian food establishment is responsible for a "medium risk" product and is seeking registration in CIFER, the CFIA requires the establishment to be licensed under the SFCR, even if the product is exempt from domestic SFCR requirements.

Dry storage establishments

The CFIA understands that Canadian dry storage establishments are only exempt from registration with GACC if they do not conduct activities which require a licence under the SFCR.

Live animals

Canadian establishments that only ship live animals or live fish/seafood products to China do not need to be registered in GACC's CIFER system at this time.

Low risk establishments

The CFIA understands that GACC approves "low risk" food and agrifood establishments without CFIA involvement. Therefore, any Canadian establishment classified as "low risk" by GACC may be either licensed or unlicensed in Canada according to existing domestic SFCR requirements.

Product specifications

Market access restrictions

Canadian establishments may only request addition of foods or agrifood products to their CIFER profiles or to GACC's listing registration if Canada currently has market access to China for those products.

Product registrations, updates, and renewals

Food and agri-food establishments must initially submit "Applications for registration" for all of their products that are exported to China, either in CIFER or through the listing registration process managed by MAS.

All product additions must be approved by GACC in CIFER or posted on the GACC listing registration website prior to export to China.

Product registrations are updated with GACC via the "Application for modification" process in CIFER.

Product registrations are renewed via the "Application for extension" process in CIFER.

High risk products

For information regarding the export of "high risk" food products to China please refer to the Food export requirements library webpages for meat and poultry, fish and seafood, and milk and dairy.

For the list of "high risk" products, as categorized by GACC, please refer to China's decree 248 – list of high and medium-risk products.

Medium risk products

For the lists of "medium risk" products, both those requiring registration in CIFER, and those requiring listing registration, please refer to China's decree 248 – list of high and medium-risk products.

Low risk products

The CFIA understands that all remaining foods not classified by GACC as either "high risk" or "medium risk", are classified by GACC as "low risk"

Packaging, labelling and marking requirements

Changes as of January 1, 2022

The inner and outer packaging of any food product exported to China should have strong, clear, and legible Chinese and English or Chinese and export country (region) text marks, indicating the following:

For products entering directly into the domestic consumer market in China: the labelling requirements must be implemented item by item

For products not entering directly into the domestic consumer market in China (including raw materials for processing and re-export): pallets, containers and shipping cabins may be used as independent packaging units to indicate the labelling requirements

Liners do not require labelling as per the decree requirements

Establishment registration number on packaging

Foods produced on or after January 1, 2022, shall be marked on the inner and outer packaging with GACC-issued China registration number or the CFIA-issued establishment identification number.

It is the responsibility of Canadian establishments and exporters to communicate with their importers in China to ensure that packaging, labelling and markings meet Chinese import requirements.

Note: the packaging and labelling requirements of foods produced before January 1, 2022, shall follow the original requirements prior to decrees 248 and 249.

Documentation requirements (non-CIFER)

Export certificates

At this time, GACC has not communicated any new or changed export certificate requirements for either "medium risk" or "low risk" food products with respect to sanitary, health, or food safety certification.

Export certificates for honey, honey related products, and bee products for human consumption

Exporters should submit a Food Export Certification Application Request to their local CFIA office to request the following documents:

Exporters of other honey related products and bee products for human consumption, such as flavoured honey, honeycomb (comb honey), royal jelly, bee propolis, and bee pollen, should either access My CFIA to obtain, or contact their local CFIA office to request, a Certificate of Free Sale (CFIA/ACIA 5786)

Phytosanitary certificates

Some plant products may require phytosanitary certification by CFIA Plant Health prior to export to China. Exporters should contact their local CFIA office well in advance of export to verify whether a phytosanitary certificate is required for specific plant product exports to China.

Canada currently has market access to export the following fresh fruit and vegetable products to China:

Note: exporters intending to export the above products to China should contact their local CFIA office well in advance of export to discuss the specific activities required to meet China's requirements.

Other information

Audit by GACC

The CFIA advises that food and agri-food establishments which are registered in CIFER to facilitate exports to China may be subject to audits by GACC at any time. CFIA anticipates that the objective of GACC auditors will be to verify establishment compliance with China's regulatory requirements, but the scope of potential future foreign audits is unknown at this time.

GACC general information

Further information on import requirements can be obtained from GACC. The CFIA encourages Canadian establishments to work with their importers in China to confirm the regulatory requirements of food and agri-food shipments prior to export.

Market access enquiries

If Canadian establishments have questions or are seeking support regarding Canada's market access to China for certain food or agri-food products, they should contact the AAFC-MAS single window at aafc.mas-sam.aac@agr.gc.ca.

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