China (People's Republic of) - CIFER - Guidance for industry

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1. Registering establishments with China using CIFER

The China Import Food Enterprise Registration (CIFER) system was developed by the General Administration of Customs of the People's Republic of China (GACC) to facilitate online registration of foreign establishments which manufacture, process, or store food and agri-food products prior to export to China. Canadian food and agri-food businesses which only export products and do not manufacture, process, or store products do not require registration with GACC.

Food and agri-food products have been classified into 3 risk categories by GACC, namely "high risk", "medium risk", and "low risk".

As of January 1, 2022, Canadian establishments which conduct the above activities must be registered in CIFER prior to the export of their products. The registration of establishments with respect to "high risk" and "medium risk" food and agri-food products involves preliminary reviews by the Canadian Food Inspection Agency (CFIA) prior to approval by GACC. For background information on China's new food requirements, please refer to New establishment registration requirements for food exports to China (Decrees 248 and 249).

The registration of establishments responsible for exclusively "low risk" products is performed by GACC alone and does not involve the CFIA. For more information on "low risk" products please refer to the food export notice China Decrees 248/249 – Registration of low-risk food product companies.

CFIA food inspectors will provide support to Canadian establishments, as necessary, to facilitate establishment registrations in CIFER. If you do not have an existing CIFER account, please note the following pre-requisites:

2. Before creating your CIFER account

Safe Food for Canadians licence

  • Establishments must obtain a CFIA licence issued under the authority of the Safe Food for Canadians Regulations (SFCR):
    • note: CFIA recommends that, if possible, the address on the Safe Food for Canadians (SFC) licence should match the address of the establishment as entered in CIFER
      The address should be the physical location of the establishment.
    • your SFC licence must include the activity of 'preparing food for export'.

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, the CFIA is the competent authority.

"Low risk" establishment identification numbers

  • Canadian establishments responsible for "low risk" products do not require a CFIA issued identification number to create an account in CIFER
  • "low risk" establishments may choose to submit a SFCR licence number to GACC as their "overseas registration number", although not recommended according to reasons in the section below, or they can use any number of their choice

Note: "low risk" establishments who intend to request CFIA-issued export certificates (for example, a Certificate of Free Sale) must obtain a SFC licence prior to export.

"Medium risk" and "high risk" establishment identification numbers

  • "Medium risk" and "high risk" establishments must enter their Canadian establishment identification (ID) number (usually termed "registration number of country" in CIFER) when creating their account in CIFER
    • CFIA recommends that establishments use a number other than their SFC licence number as their establishment identification number (registration number of country) when creating their CIFER account. Other CFIA issued numbers are available as follows:
      • a registration number that was issued by the CFIA prior to the SFCR (pre-2019) or
      • a 4 character CFIA establishment ID number that may be requested by contacting your local CFIA office

Note: "medium risk" and "low risk" establishments may use their 8 character SFC licence number as their establishment ID number. However, use of the SFC licence number for CIFER account creation is not recommended as establishment identification numbers cannot be amended in CIFER after an account is created. In addition, an establishment's SFC licence number can be subject to change under certain circumstances, for example when a SFC licence expires without renewal in advance of the expiry date.

Note: "high risk" establishments should only use 1 of the above 2 options and should not use their SFC licence number to create their CIFER accounts.

Creating an account in CIFER

  • Establishments will create their CIFER account using the following information:
    • their full legal name as it appears on their Safe Food for Canadians (SFC) licence
    • their CFIA-issued establishment ID number
    • any other information as requested by GACC
    Note: establishments are advised to be careful when creating their CIFER accounts as GACC does not allow future modification of certain fields in CIFER such as the Canadian establishment ID number and the physical address of the establishment.

Tip: when completing an application in CIFER, establishments are encouraged to utilize the CFIA's Checklist Tool to help guide them through the application and ensure all required information is included.

3. Account certification

  • "Low risk" establishments do not require CFIA account certification
  • They can proceed directly to submitting applications in CIFER for low risk products
  • CIFER accounts for "medium risk" and "high risk" establishments must first be "certified" by the CFIA in the system before the establishment has the ability to create applications for their "medium risk" or "high risk" products
  • Establishments that are not "certified" are limited to creating applications for "low risk" commodities only
  • Establishments must contact their local CFIA office to request that their self-created CIFER accounts be "certified" by CFIA
  • The establishment's email request for CIFER account certification must include:
    • full legal name of the establishment as it appears on their SFC licence
    • establishment physical address as entered in MyCFIA and CIFER which must match each other
    • the specific CFIA-issued establishment ID number that was used to create their establishment's CIFER account
  • Upon receipt of this email, the CFIA will acknowledge receipt of the request and proceed to certify the establishment's CIFER account
  • The CFIA local office will advise establishments once their CIFER account has been certified by CFIA
  • Establishments which have been certified are able to proceed with creating applications for registration for their "medium risk" or "high risk" products

Tip: when completing an application in CIFER, establishments are encouraged to utilize the CFIA's Checklist Tool to help guide them through the application and ensure all required information is included.

4. Creating and amending product applications in CIFER

What is an "application" in CIFER

To be able to export to China, establishments must register their products with GACC prior to export. Each category of product that an establishment wishes to export must be registered with GACC in their CIFER account.

Establishments must create "applications" for product registrations in the CIFER system for submission to CFIA if the establishment is responsible for the manufacturing, processing, or storing of "medium risk" and "high risk" food and agri-food products.

Product applications in CIFER will be 1 of the following 2 types

  1. Application for registration in CIFER
    • A separate "application for registration" must be completed in CIFER for each product category an establishment wishes to export to China
    • Establishments are responsible for working with their importers in China to determine the correct Harmonized System (HS) Codes and China Inspection and Quarantine (CIQ) Codes for each product in CIFER that they intend to export
    • The CFIA is unable to provide guidance on which HS and CIQ codes should be entered in CIFER
    • Establishments should be prepared to upload to CIFER detailed documentation regarding their establishment and their product(s)
    • Examples of documents that may be required by GACC include, but are not limited to:
      • valid SFC licence (sometimes termed a "production certificate" in CIFER)
      • establishment floor plan
      • Hazard Analysis Critical Control Points (HACCP) plan
      • product package or label photos
      • Genetically modified organisms (GMO) or non-GMO certification document
      • process flow charts
      • any other supporting documents which demonstrate compliance with China's regulatory requirements for food or agri-food products or which assist GACC in determining establishment or product compliance
  2. Application for modification in CIFER
    • If an establishment needs to make amendments to an approved registration, they will need to submit an "Application for Modification" in CIFER
    • The modification process can include changing a name, removing products or adding additional products for GACC approval under a product category in which the establishment is already registered
    • The process in CIFER to complete an "Application for Modification" is the same as that for the "Application for Registration"

Note: GACC does not allow modification of certain fields of a registration in CIFER such as the establishment ID number and the address of the establishment

Tip: when completing an application in CIFER, establishments are encouraged to utilize the CFIA's Checklist Tool to help guide them through the application and ensure all required information is included.

5. Cancelling a registration in CIFER

Establishments wishing to cancel an entire product category registration (for example, poultry, grain products, aquatics, or other categories) must submit an "Application for cancellation".

If an establishment only needs to remove a specific product within a category but not the entire category, then an "Application for modification" should be submitted.

Tip: when completing an application in CIFER, establishments are encouraged to utilize the CFIA's Checklist Tool to help guide them through the application and ensure all required information is included.

6. Renewing registrations in CIFER

Timing

Registrations in CIFER are typically valid for a period of 5 years. However, establishments which were on a China eligibility list prior to the implementation of CIFER, will have an expiry date that is sooner than 5 years.

Establishments are responsible to note the expiry date of their approved registration on the CIFER Query page to ensure they do not miss the renewal deadline set by GACC. The "Application for extension" is only available for the 3 to 6 month period before the expiry date. This means that exactly 3 months before the expiry date, the "Application for Extension" button in CIFER will no longer be available to establishments in CIFER. Establishments will need to contact their local CFIA office after submitting an "Application for extension" to advise of its submission.

Process

GACC has advised CFIA that all establishments that were registered in CIFER by GACC (that is, did not self-register in CIFER after January 1, 2022), must update their registrations in CIFER with an "Application for modification", prior to completing the renewal process via an "Application for extension". The "Application for modification" must be approved by GACC before an "Application for extension" can be submitted. Regardless of registration expiry date, all establishments registered by GACC in CIFER (that is, did not self-register in CIFER), must update their registrations in CIFER by submitting an "Application for modification" as soon as possible in 2023. This includes all "medium risk" establishments with expiry dates in 2026 and 2027.

Tip: when completing an application in CIFER, establishments are encouraged to utilize the CFIA's Checklist Tool to help guide them through the application and ensure all required information is included.

7. After an application has been submitted to CFIA in CIFER

Once establishments have submitted their applications (either new, renewals or amendments) in CIFER, they will need to contact their CFIA local office by email to advise that they have submitted an application in CIFER. In the email, establishments must supply all of the information that CFIA requires to complete its assessment, specifically:

  • company name as it appears in the CIFER application
  • establishment physical address
  • the establishment ID number used to create the establishment's CIFER account
  • a list of the of the specific products or product types in the application(s)
  • screen capture of the application status and the list of uploaded documents, found at the top of the page, showing that the application has been submitted to CFIA
    If submitted properly, the status should say "current state: Submit to authorities"

The CFIA local office will acknowledge receipt of the email with the above information.

Review of applications by CFIA is a multi-step process. Once the initial application is received and reviewed by CFIA in CIFER, establishments will be provided with 2 documents via email from the local CFIA office that must be completed and submitted back to CFIA, specifically:

  • a CFIA "Application form for registration in China's CIFER system" for signature by the establishment's legal representative which authorizes the CFIA to submit the establishment's applications to GACC on their behalf and which also functions as a legal waiver of CFIA liability related to applications for registration to GACC
  • a lengthy GACC product-type specific inspection checklist
  • please note the following requirements; each checklist must:
    • provide both the establishment ID number and the SFC license number, if applicable
    • have the signature of the establishment's legal representative and the company seal/stamp appear at the bottom of each page (see notes below)
    • be returned to the CFIA local office in electronic format, such as PDF, via email
    • be a file size of less than 4 MB (in other terms, the file size must be less than 4,000 KB)
  • once all required documentation is received and the application is reviewed and deemed complete, CFIA will submit the application to GACC within CIFER

Note: for the purpose of CFIA enabling CIFER registration by an establishment, the "legal representative" is a person who is legally responsible for the establishment. An establishment's legal representative must be the same person whose name appears on any document uploaded to CIFER.

Note: a company seal is an official sticker bearing the company logo or other official graphical identifier that would be applied on company documents. A company stamp is an official company imprint of such a graphic, often in ink and applied with a stamping device, or its digital equivalent.

8. GACC review of applications for product registration

After CFIA submission of applications, GACC's timeline for review is unpredictable.

It is common for GACC to return applications due to incompleteness or errors, such as: missing documents from the uploaded documents package; improper formatting (for example, missing signatures or seals/stamps); or other corrections that need to be performed by the establishment.

After GACC identifies problems and returns the application, establishments are responsible for uploading missing documents as well as deleting incorrect documents and uploading their corrected versions within CIFER. Then their applications must be resubmitted to the CFIA. After an application has been corrected and resubmitted in CIFER by establishments, they must notify their CFIA local office via email that they have resubmitted their application. After review for completeness and correctness, CFIA will submit the corrected application to GACC within CIFER.

9. Establishment monitoring of applications in CIFER

Following a submission, establishments should monitor their CIFER accounts often to watch for changes in their application status. Common application statuses can include, but are not limited to:

  • "To be corrected by enterprise": the application has been returned for correction

    Establishments can view the reason the application has been returned by going to "Integrated Query" > "Application Form Query" and clicking the word "View" under either the "Customs Feedback" column (if returned by GACC") or the "Institutional Feedback" column (if returned by CFIA) . Establishments may contact their CFIA local office if assistance is needed to address any corrections required.

  • "Waiting for acception" or "Being accepted by the GACC": the application has been submitted to GACC and is currently under review

    No further action by the establishment is required at this time.

  • "Refused by GACC":  the application has not been approved by GACC

    The reason the application has been refused can be viewed by going to "Integrated Query" > "Application Form Query" and clicking the word "View" under the "Customs Feedback" column. Establishments will have to create and submit a new application in CIFER (making the requested amendments) and then notify their CFIA local office when submitted.

  • "Approved": the application has been approved by GACC

    See GACC approval of applications below for details.

10. GACC approval of applications

Application "Approved" by GACC in CIFER

When GACC approves a new "Application for registration", the establishment will be assigned an 18-digit China registration number for that product category and a new entry will appear on the CIFER Query list. At this time, the establishment is able to request an export certificate to export the products approved in the registration.

When GACC approves an "Application for modification", some changes such as the addition or removal of products will not show in the CIFER Query list while others, such as a name change, will be reflected in the CIFER Query list.

When GACC approves an "Application for extension", the registration expiry date will be updated in the CIFER Query list.

Note: it is important that export documentation accompanying shipments reflects the information that is currently in CIFER. Information mismatches between export documents and the information in CIFER can create problems for shipment clearance upon arrival in China.

11. Verifying GACC approval of product categories and products

Within their CIFER accounts, establishments can view their GACC-approved registrations in 3 ways:

  • on the main menu select "Integrated Query" and then select "Registration Information" to view the registrations for each GACC approved product category
  • on the main menu select "Application for Registration"

    If you select a product category for which you are already approved by GACC, the completed application will open. If you are not approved for that product category, a blank application form will open.

  • on the main menu select "Application for Modification"

    A list of any GACC approved registrations should appear. The current approved application will open by selecting the "Modify" function for the product category you wish to view.

Within any of the 3 options above, establishments can view the product HS Codes and CIQ Codes for which they are approved by GACC to export to China by viewing the list under the section "Qualification obtained of Registered in China".

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.

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