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

On this page

• Eligible/ineligible product
• Pre-export approvals by the competent authority of the importing country
• Product specifications
• Production controls and inspection requirements
• Packaging, labelling and marking requirements
• Documentation requirements

Eligible/ineligible product

Eligible

• Raw milk
• Pasteurized milk
• Sterilized milk
• Modified milk
• Fermented milk
• Evaporated milk, sweetened condensed milk, formulated condensed milk
• Milk powder
• Whey powder and whey protein powder
• Cream, butter and anhydrous milk fat
• Cheese
• Processed cheese
• Infant^Footnote 1 formula

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

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 CFIA local office

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.
• 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.

Product

• 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 (in 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 and the standard health certificate can be issued. Furthermore, China also requires a certificate of origin for these products. The exporter can obtain this document from the Canadian Chamber of Commerce. The CFIA does not need to review this document.

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

Production controls and inspection requirements

• The CFIA inspector confirms that the information submitted with the application is complete and accurate for the products listed for export to China. The information is verified during regular inspection visits to ensure that the establishment is meeting China's export requirements prior to recommending that a new plant be added to the eligibility list
• Manufacturer's declaration letter must accompany the export certificate request for dairy products
• The letter should state that exporter and/or manufacturer are aware of China's dairy standards and requirements and that a specific export procedure to the product that will be exported to China was developed

Packaging, labelling and marking requirements

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

Documentation requirements

Certificate

• Health Certificate for the export of dairy and dairy based products for human consumption from Canada to the People's Republic of China
  • Note: Health certificate 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
• Standard health certificate for ice cream
• Manufacturer's declaration for export to China (industry responsibility)