China (People's Republic of) - Export requirements for all other foods and agri-food products
On this page
- Eligible/ineligible products
- Pre-export approvals by CFIA
- Pre-export approvals by competent authority of importing country - China Import Food Enterprise Registration (CIFER) system
- Product specifications
- Packaging, labelling and marking requirements
- Documentation requirements (non-CIFER)
- Other information
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".
- Canada has market access to China for almost all "medium-risk" and "low-risk" food products as per the Product specifications section
- Most raw grains can be exported to China except for those listed in the Ineligible products section
- For fresh fruits and vegetables, Canada only has market access for the following products at this time:
Note: For information on "high-risk" food products for export to China, please refer to the individual product type webpages for meat and poultry, fish and seafood, and milk and dairy products in the Canadian Food Inspection Agency's (CFIA) Food export requirements library.
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:
- lentils (raw grain)
- chickpeas (raw grain)
- fababeans (raw grain)
- adzuki beans (raw grain)
- oats (raw grain)
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: email@example.com.
Pre-export approvals by CFIA
Pre-export approval by CFIA required under China Decrees 248 and 249
- As of January 1, 2022, all "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 registration with GACC in the CIFER system
Licencing under the Safe Food for Canadians Regulations
- "Medium risk" establishments wishing to be approved by GACC as eligible in the CIFER system must first be licenced 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 storage warehouses, are also subject to preventive control plan (PCP) requirements under the SFCR
- Establishment SFCR licences must include either of the activities "exporting food" or "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 CFIA local office
Medium risk establishment identification numbers
- 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.
- GACC also assigns a lengthy "China registration number" to all foreign establishments which become registered in the CIFER system.
"Medium risk" establishments require a CFIA-issued establishment identification number
- The establishment identification number can be either:
- a CFIA-issued four character identification number; or
- a registration number that was issued prior to the SFCR, that is, a registration number that was issued by the CFIA prior to 2019; or
- a CFIA-issued SFCR licence number.
Note: "Medium risk" establishments are recommended to request a 4 character identification number through their CFIA local office.
- The establishment identification number can be either:
Low risk establishment identification numbers
- Canadian establishments responsible for "low risk" products do not require a CFIA issued identification number to submit to GACC.
- For example, "low risk" establishments may choose to submit a SFCR licence number to GACC as their "overseas registration number", but they can use any number of their choice.
Pre-export approvals 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 licencable activities must:
- have a profile (also known as an account) in the CIFER online system
- a CIFER profile can be directly created by establishments
- request to have their profile in CIFER "certified" by CFIA
- a CFIA "certified" profile allows establishments to submit an application for registration
- become individually approved by GACC, including the registration of their products, in CIFER
- have a profile (also known as an account) in the CIFER online system
- 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 GACC 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 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 return the application to the establishment for amendments, as required
- GACC returns applications to establishments within CIFER when corrections are necessary. 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:
- create their own profile (also known as an account) in the CIFER online system
- add their "low risk" products to their profile
- 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.
- At this time, GACC has not communicated whether previously published establishment eligibility lists will continue to be valid or updated in coordination with updates to establishment eligibility statuses in CIFER under the authority of Decrees 248 and 249.
- Some food establishments are exempt from domestic Canadian licencing under the SFCR because of the type of product they produce, process, or manufacture, for example, alcoholic beverages, 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 with GACC, the CFIA requires the establishment to be licenced 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.
- 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 at this time. Therefore, any Canadian establishment classified as "low risk" by GACC may be either licenced or unlicensed in Canada according to existing SFCR requirements.
Market access restrictions
- Canadian establishments may only add food or agrifood products to their CIFER profiles for which Canada currently has market access.
- In CIFER, food and agri-food establishments must submit requests for registration for all of their products that are exported to China
- All product additions must be approved by GACC in CIFER prior to export
High risk products
For information regarding the export of "high risk" products please refer to the Food export requirements library 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.
5.4 Medium risk products
For the list of "medium risk" products, as categorized by GACC, 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:
- origin of the food
- 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)
- 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:
- Request for inspection to obtain an export certificate – Honey (CFIA/ACIA 2659)
- Exporter's declaration for the export certificate (CFIA/ACIA 2659) – Honey
Note: Each lot of honey must be graded prior to issuance of a CFIA export certificate (CFIA/ACIA 2659).
- 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 MyCFIA to obtain, or contact their local CFIA office to request, a Certificate of Free Sale (CFIA/ACIA 5786)
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.
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 firstname.lastname@example.org.
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