China (People's Republic of) - Export requirements for fish and seafood

On this page

• Eligible/ineligible product
  • Fish and seafood products eligible to be exported to China
• Pre-export approvals by competent authority of importing country
  • Export of live aquatic animals to China
  • Export of non-live aquatic animals to China
• Product specifications
• Packaging, labelling and marking requirements
• Documentation requirements
• Other information
• Appendix A - Request for addition to the list of eligible countries (areas) and aquatic products approved for exporting to China

Eligible/ineligible product

Eligible

• All fish and seafood products for species that have been approved for export to China (please see below for full list of approved live and non-live products eligible to be exported to China)

Fish and seafood products eligible to be exported to China

• Establishments can only export live and non-live fish and seafood species which have been approved for export to China
• Exporters are encouraged to confirm with Chinese importers that they meet China's requirements prior to exporting
• The following lists are implemented by the General Administrations of Customs of the People's Republic of China (GACC) and their China Inspection and Quarantine (CIQ) branches at ports of entry:
  • Live species: List of live aquatic animals (by family) approved for export to China (available in Chinese only – food products located on first tab)
  • Non-live species: List of non-live aquatic animals (by species) approved for export to China (available in Chinese only)
• Canada's approved products can be found by searching 加拿大 in either above list
• To add a product to either list, establishments are asked to provide the following information to their local CFIA office: product name (scientific, common), processing method (live, fresh/chilled, frozen, fish roe, fish oil, etc.), production method, territorial waters, country of origin, estimated annual production in Canada and estimated annual export volume to China
• See Appendix A for more details

Ineligible

• Edible seal products

Pre-export approvals by competent authority of importing country

Export of live aquatic animals to China

List of Canadian Live Aquatic Animal Establishments Registered to export to China

In order to export to China, establishments who process, label, pack and/or store live aquatic animals must appear on China's List of live aquatic animal establishments registered to export to China (available in Chinese only) administered by GACC.

• The link above will open to a Chinese webpage. Do not click the "English" button in the top right corner of the page as this will take you to a separate webpage.
• Canada's approved list can be found by selecting "加拿大输华水生动物注册登记企业" in the provided list.
• After selecting the appropriate link, open the zip file and follow the folder chain.
• Select the Microsoft Excel document.

Procedure to add, modify or delete a live aquatic animal establishment registered to export to China

The CFIA must recommend the approval of establishments for listing by GACC

Please contact your local CFIA office to initiate a request in writing and include the following information:

• unique establishment ID
• Safe Food for Canadians licence number
• full legal name as it appears on the Safe Food for Canadians licence
• physical site address associated with the unique establishment ID
• product details:
  • Animal species (Mollusca, Crustacean, Echinoderm, or Fish)
  • Type: wild or aquaculture

It is important to note that the Government of Canada has no control or advance knowledge as to when GACC will publish future versions of this updated list on its website.

Note: Before final approval, GACC may request additional information and/or audit the establishment.

Establishments that export only live aquatic animals do not need to be registered in the China Import Food Enterprise Registration (CIFER) system.

Establishments involved in the export to China of both live and non-live products prior to export to China must be on the List of live aquatic animal establishments posted on GACC website and also be added to the establishment's account in CIFER

Export of non-live aquatic animals to China

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"
• Note: fish and seafood products are classified by GACC as "high risk" foods
• Establishments that only ship live fish and seafood products do not need to appear in GACC's establishment list in the China Import Food Enterprise Registration (CIFER) system at this time
• Establishments wishing to be on GACC's eligibility list in the 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 fish and seafood to China for human consumption, all fish establishments, including fishing vessels (involved in the production and processing of fish), and cold or dry storage warehouses must:
  • have an account (a profile) in the CIFER online system operated by GACC
  • have their account 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

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 if required
• GACC conducts its own reviews and approvals, the timelines for GACC's review and approval processes are often lengthy and variable
• When an establishment that is already on the list 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
• CFIA is unable to implement any changes to the CIFER system or processes
• Note: Further information on CIFER applications can be found in the Industry Guidance

Verifying establishment registration in CIFER

A list of all registered enterprises can be found in the CIFER query system

Product specifications

Maximum levels for chemical contaminants

• Lead: 0.5 ppm
• Inorganic arsenic: 0.1 ppm for finfish / 0.5 ppm for all other fish
• Cadmium: 0.1 ppm (finfish only)
• Total PCB: 2.0 ppm (sum of PCB congeners #28, 52, 101, 118, 138, 153 and 180)
• PCB 138: 0.5 ppm
• PCB 153: 0.5 ppm

Maximum levels for therapeutants and antibiotics

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 goods and scientific name
  • specifications
  • production date
  • lot number
  • shelf life
  • storage conditions
  • production method (seawater fishing, freshwater fishing, aquaculture)
  • production area (ocean fishing areas, freshwater fishing countries or regions, countries or regions where the aquaculture products are located)
  • all production and processing enterprises involved (including fishing vessels, processing vessels, and transport vessels and an independent cold store) name, registration number and address (specific to the state/province/city)
  • the destination must be marked as the People's Republic of China
• For aquatic products entering directly into the domestic consumer market the labelling requirements must be implemented item by item
• For products not entering directly into the domestic consumer market (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
• If the liner is a 'closed plastic bag', an inner label is required to be attached to the bag.
• If the liner is 'not closed', an inner label is not required.

Note: the packaging and labelling requirements of foods produced before January 1, 2022, shall follow the original requirements that were in place prior to the implementation of Decrees 248 and 249.

Establishment Registration Number on packaging:

• Fish and seafood 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

Note: exporters are responsible for ensuring that the establishment is eligible to ship the products being certified. Exporters may contact their local CFIA office for information on how to add additional products if they want to ship products that they are not currently approved for in CIFER.

1. For fresh and frozen products including bivalve molluscan shellfish: Health Certificate for Fishery products intended for export from Canada to the People's Republic of China (CFIA/ACIA 5328).
   The following information must be included on the certificate:
   • the appropriate CFIA (Canadian Food Inspection Agency) operational area, that is to say, Atlantic Canada, Quebec Canada, Ontario Canada, or Western Canada, under Section 11(2). Origin of fishery products, "Production Place"
   • for all caught fish, the name and registration or licence number^Footnote 1 of all of the fishing vessels used to harvest the fish as well as the FAO fishing area
   • for all aquacultured fish, the name and address of 1 of the fish farms where the fish were raised
   • under Section II(2): Origin of the fishery products, "Name(s), registration/licence number(s) and address(es) of all producing and processing enterprise(s), factory vessel(s), cold store(s) or freezer vessel(s) registered by the CFIA for export to the People's Republic of China"
     • For example, if a product was processed at 1 establishment and then stored at a cold store, both facilities would need to be identified on the certificate
2. For live product, including live bivalve molluscan shellfish: Origin and Hygiene Certificate for live fish intended for export for human consumption from Canada to the People's Republic of China (CFIA/ACIA 5584).
   The following information must be included on the certificate:
   • For all live bivalve molluscs:
     • The fishing area and the harvest area beside the header: Section II. "Origin of the fishery products"
     • For Canadian harvest areas, the harvest areas as they appear on the List of Canadian commercial bivalve harvest areas must be indicated
   • For live crab harvested in FAO Area 67:
     • The fishing area and the sub-area beside the header: Section II. "Origin of the fishery products"
       • For example, indicate FAO Area 67 (British Columbia, Oregon, Washington or Alaska)
     • In Section II. "Origin of fishery products", Name(s), registration/licence number(s) and address(es) of all applicable producing and processing enterprise(s), factory vessel(s), cold store(s) or freezer vessel(s) registered by the CFIA for export to the People's Republic of China"
       • For example, if a product was processed at 1 establishment and then stored at a cold store, then both facilities would need to be identified on the certificate

For all other live products:

• Information on the fishing area is optional and can be included on the certificate by the exporter.
• If a fishing area is included, it must be added beside the header: Section II. "Origin of the fishery products"

Other information

Further information on import requirements can be obtained from the General Administrations of Customs of the People's Republic of China (GACC).

Appendix A - Request for addition to the list of live or non-live aquatic animals approved for export to China