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Archived - New establishment registration requirements for food exports to China (Decrees 248 and 249)

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New establishment registration requirements

Effective January 1, 2022, establishments that manufacture, process, and store food products for export to China need to comply with 2 new Chinese regulations for imported food and overseas food establishments.

Canadian food establishments must be licensed under and be in compliance with the Safe Food for Canadians Regulations (SFCR) as well as with China's regulatory requirements prior to export.

As part of China decrees' registration requirements, foreign establishments or fish/seafood processing vessels involved in the production, processing, or storage of any food product exported to China must be registered by the General Administration of Customs China's (GACC) in the China Import Food Enterprise Registration (CIFER) system.

The Canadian Food Inspection Agency (CFIA) continues to seek clarity from GACC on establishment registration and amendment processes and functionality of GACC's CIFER system.

Action for Canadian companies

It is critical that Canadian establishments register with GACC in the CIFER system prior to export. This includes, fish/seafood processing vessels involved in the manufacture, processing, and cold storage of food products that are exported to China.

The CIFER system and the registration requirements are administered by GACC.

GACC's new registration process is required in order for foreign establishments to maintain or obtain access to the Chinese market for food products.

Once registered in CIFER, establishments need to ensure their shipments meet the label requirements of Decree 249. Key changes include that foods must be labelled on the inner and outer packaging in Chinese, or Chinese and English (Decree 249, Article 30) and bear either the CFIA-issued establishment ID number or the GACC-issued registration number. The GACC-issued registration number will be assigned to the establishment in the CIFER system and begins with the letters "CCAN".

Establishment registration renewal

Establishments registered in the CIFER system must renew their registration every 5 years. Registered establishments need to note their expiry date in the CIFER system and begin the renewal process 3 to 6 months in advance of the expiry date to minimize the risk of interrupting trade.

GACC categorizes establishments by risk depending on the products exported from those establishments. The following risk categories have been defined by GACC.

High-risk products

For Canadian establishments on existing eligibility lists for " high-risk" products, GACC already created their CIFER profiles and logins; these companies remain eligible to export. However, the management of new registrations and amendments is now entirely done in CIFER.

Establishments must confirm their information in CIFER and update it and/or correct any errors. Amendments to existing registrations (for example, add a product) require establishments to complete a registration package in CIFER for verification by CFIA, followed by CFIA submission to GACC.

New establishments must contact their local CFIA office and create a CIFER profile and login, before an application process can begin.

For the list of "high-risk" commodities, please refer to China's Decree 248 – list of high and medium-risk products.

Medium-risk products

In October 2021, the CFIA compiled basic profile information submitted by Canadian "medium-risk" product establishments. CFIA assigned unique identification numbers (where necessary) and transmitted lists of recommended establishments for medium-risk product types to GACC. Establishments must confirm their information in CIFER and update it and/or correct any errors. Amendments to existing registrations (for example, adding a product) require establishments to complete a registration package in CIFER for verification by CFIA, followed by CFIA submission to GACC. New establishments must contact CFIA to request CFIA creation of a CIFER profile and login, before an application process can begin.

"Medium-risk" food product establishments which missed the October 2021 submission and who are planning to export to China should contact their local CFIA inspection office.

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

Low-risk products

All food and agri-food products for export to China, other than "high-risk" and/or "medium-risk" products described above, are considered "low-risk" products by China and must self-register directly with CIFER.

Note: GACC has advised that establishments which have previously registered for "high-risk" or "medium-risk" and also export "low-risk" products, do not need to self-register again.

For more information on the implementation process and what is required by Canadian businesses, please see the food export notices.

New market access requests

Questions on how to request new market access to China must be sent to aafc.mas-sam.aac@agr.gc.ca.

For more information

For specific requirements by food commodity, visit the China section of CFIA's Food export requirements library.

Summary of changes to the China establishment eligibility listing process

Then and now
Action Before January 01, 2022 January 01, 2022 onward
Before submitting an application N/A

All establishments that manufacture, process, or store (cold or dry) food products intended for export to China are required to have an account in CIFER.

Establishments which do not yet have a CIFER account will need to create one.

Establishments of only "low-risk" products: Create your account in CIFER

Establishments of "medium-risk" products (may also export "low-risk" products): Contact your local CFIA office to obtain a CFIA establishment number before creating an account in CIFER.

Establishments of "high-risk" products (may also export "medium-risk" products and/or "low-risk" products): Use the 4 or 7 digit CFIA-assigned establishment identifier to create an account in CIFER.

Note: Establishments can only hold 1 CIFER account per physical location but can register multiple product categories under 1 account.

CIFER account certification N/A

Accounts involving only "low-risk" products do not require account certification by CFIA.

Accounts involving "medium-risk" products and/or "high-risk" products must contact their local CFIA office to request CIFER account certification.

The requestor/establishment should monitor their CIFER account(s) for status of the certification as CIFER does not provide confirmation emails.

Submitting an application for registration or application for modification Establishments contacted local CFIA office with a written/email request for registration or modification with all relevant supporting documentation.

Log in to the applicable account in CIFER and select "Application for Registration" or "Application for Modification", as appropriate. Select the applicable product category. Complete the application by uploading the required information and supporting documents.

Applications for low-risk products will be submitted in CIFER by establishments directly to GACC for review and approval.

Applications for medium-risk and/or high-risk products are submitted in CIFER to the CFIA for review and approval. Applicants must inform their local CFIA office once the application has been submitted and provide a screen shot of the completed "Attachment Information" from the application.

While CFIA is reviewing the application in CIFER, establishments will be provided with an application form and checklist (new applications only) for completion.

CFIA will submit the final application to GACC if the request is complete and all required documents are received.

Submitting an application for extension (renewal) N/A To be determined – GACC has not yet provided details on this process. It is recommended renewals be completed 3 to 6 months prior to expiry date.
Submitting an application for cancellation Establishments contacted local CFIA office with a written request to cancel establishment registration

Log in to applicable account in CIFER. Select "Application for Cancellation" from the menu. Select "Cancel" button next to appropriate registration number(s).

Accounts with multiple product registrations will have the option to cancel individual product categories.

Publication of establishment information Establishment eligibility list updates were published on GACC website Establishment eligibility lists and basic information on each establishment are published for public viewing in the CIFER query system. Whether GACC will maintain establishment information in other places on the web remains uncertain.

Questions

Contact CFIA Food Export at FE-AE@inspection.gc.ca or speak to your local CFIA inspector.

Food export notices

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