Urgent action for fish and seafood establishments – renewals in CIFER
The General Administration of Customs China (GACC) has recently advised Canadian Food Inspection Agency (CFIA) that all establishment registrations predating January 1, 2022 must be updated in the China Import Food Enterprise Registration (CIFER) system prior to being able to complete the renewal process. GACC requires that establishments renew their registrations at least 3 months in advance of expiry.
The eligibility of all Canadian fish and seafood establishments currently exporting non-live fish and seafood to China and that are registered in CIFER will expire on December 31, 2022. Should your establishment fall into this category and you wish to continue exporting to China, it is imperative that you begin the process of updating your CIFER registrations immediately.
This means that fish and seafood establishments must complete and submit both an "Application for Modification" and, subsequently, an "Application for Extension (renewal)" in CIFER for approval by GACC prior to September 30, 2022. (Since the deadline is now passed, submit your application for modification ASAP).
Establishments that miss the renewal deadline may be delisted, lose their eligibility to export to China, and may need to start the registration process over again.
Immediate next steps
All fish and seafood establishments that currently export non-live products to China, must log into CIFER as soon as possible and complete the following steps:
step 1: update their current registrations by completing and submitting an "Application for Modification" and filling in all missing information and attaching all requested documentation.
step 2: contact their local CFIA office by email to advise that an application has been submitted in CIFER. In the email, establishments must provide:
- full legal name as it appears on their Safe Food for Canadians (SFC) licence
- establishment physical address
- the establishment ID/registration number
- a list of the specific products or product types in the application
- screen capture of the "preview" page in CIFER that the establishment representative sees prior to submitting their application within the system
step 3: while CFIA is reviewing the application in CIFER, the company will be provided with 2 forms to complete:
- CFIA's application form for registration in China's CIFER system
- GACC product-type specific inspection checklist
step 4: once the forms have been returned to CFIA and the application has been verified as complete, the CFIA will submit the application to GACC. Note that GACC's approval process is variable and often lengthy.
step 5: establishments will need to wait until their "Application for Modification" is approved by GACC before they can submit an "Application for Extension". Establishments must monitor their accounts regularly for changes in application status.
step 6: once the "Application for Modification" has been approved, submit an "Application for Extension" and contact their local CFIA office by email to advise that a renewal request has been submitted in CIFER. In the email, establishments must provide:
- full legal name as it appears on their SFC licence
- establishment physical address
- the establishment ID/registration number
- screen capture of the "extension" page in CIFER that the establishment representative sees prior to submitting their application within the system
Attention – fish/seafood establishments: when updating the information in CIFER, establishments must:
- ensure all fields marked with an asterisk (*) are filled in
- change the "Plant Establishment Time" to the date the company first began operations in the facility
- attach a copy of the Safe Food for Canadians Regulations (SFCR) licence, facility floor plan, and process flow charts for each product that is exported to China in their designated sections in CIFER
- ensure all fish/seafood products the establishment exports to China are included in the section 'Products to be registered/added by China'. This can include products the establishment has exported to China in the last 5 years, products that are currently being exported, and/or products the establishment intends to export to China in the next year
Ensure they are using the correct China approved Harmonized System (HS)/China Inspection and Quarantine (CIQ) codes (CFIA recommends verifying these codes with the importer and/or checking the "product type query" in CIFER).
- only request approval for species/products Canada currently has access to export to China
Refer to Canada's approved list of species and products (Chinese only) Canada's approved species can be found under the heading 加拿大 (Kangxi radicals numbers 19, 64, and 37), which together are the characters for "Canada".
Note: modification requirements for other products such as meat and dairy will vary slightly from the above information.
Renewal of other food and agri-food product establishments
The GACC has recently advised CFIA that all registrations currently in CIFER (with the exception of any new establishments registered after January 1, 2022) must be updated prior to being able to complete the renewal process.
The CFIA would like to remind the Canadian industry that all registrations in the CIFER system must be renewed, at minimum, 3 months before their expiry date to remain eligible to export to China.
Most Canadian establishments that were approved to export food and food products to China prior to the implementation of CIFER (January 1, 2022) will be expiring before the end of 2023.
To confirm when your registrations expire, go to the CIFER query site and look up the establishment by querying the registration number. There is a column entitled "Registration Expire Date". It is the establishment's responsibility to know the expiry date of all registrations in CIFER and ensure that renewal requests are submitted well before the registration expires to allow for processing by the GACC. Note that the option to renew is only available in CIFER 6 months before the expiry date.
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