On October 14, 2025, the General Administration of Customs promulgated the Regulations of the People’s Republic of China on Registration Administration of Overseas Production Enterprises of Imported Foods (Decree No. 280 of the General Administration of Customs of the People's Republic of China, hereinafter referred to as the Regulations), which shall take effect on June 1, 2026. To facilitate a comprehensive understanding and accurate grasp of the regulatory amendments among concerned entities and the public, key aspects are interpreted as follows.

I. Background and Rationale for the Amendments

The previous Regulations of the People’s Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food, implemented since January 1, 2022, has played a significant role in fully enforcing the provisions of the Food Safety Law of the People’s Republic of China concerning the registration of overseas manufacturers of imported food, enhancing source safety control over imported food, and supporting the broader national objectives of diplomacy and foreign trade. However, amid China’s continuously widening opening-up, both the trade volume of imported food and the number of registration applications from overseas manufacturers have increased rapidly. It has therefore become necessary to further refine the registration management system so as to better align with the imperative of "safeguarding national security and facilitating development".

II. Key Issues for Explanation

(I) Clarifying risk management principles to enhance scientific and targeted registration management.

It is specified that Customs applies risk management principles to determine appropriate registration methods, review procedures, and other registration management requirements, based on the assessment and review of the food safety systems and overall food safety conditions in the countries where overseas manufacturers of imported food are located, as well as the risk levels of the relevant food products (Articles 5, 12, 19, etc.). Concurrently, the 18 categories of foods subject to official recommendation for registration under the current regulations have been transitioned to a catalog-based management system. This adjustment allows for dynamic updates in response to changes in risk levels (Article 6).

(II) Upholding the bottom line in food safety regulation and optimizing registration methods.

Taking into full account the feedback from WTO members, the two existing registration methods, namely "Competent Authority Recommendation" and "Enterprise Application", have been streamlined into a single approach where all applications are submitted by the enterprises themselves. However, for food items included in the Catalog of Imported Foods Requiring Official Recommendation for Registration, enterprises are required to submit inspection reports and a letter of recommendation issued by their competent authority during the application process. This helps ensure the unwavering adherence to food safety standards (Article 9). Furthermore, China will pursue deeper and broader international cooperation in the field of registration management for overseas food production enterprises. This includes the introduction of a more convenient batch-list registration mechanism. For countries (regions) that have signed food safety cooperation documents with China, their competent authorities may provide a list of enterprises deemed eligible. Based on bilateral agreements, the GACC will carry out batch registration and management of enterprises on that list (Article 17).

(III) Extending regulatory requirements across the entire chain for enhanced international co-governance in food safety.

For the batch-list registration mechanism, it is specified that the food safety management system of the respective country (region) must be recognized by the General Administration of Customs. Concurrently, the competent authorities are required to provide declarations confirming that the recommended enterprises comply with registration requirements and commit to continuously fulfilling the responsibilities agreed upon bilaterally (Articles 17 and 18). Furthermore, it is stipulated that for any enterprise failing to maintain compliance with the registration requirements, the competent authorities of its country (region) must oversee rectification, and upon completion, submit a supervision and rectification report along with a written declaration confirming compliance with the registration requirements (Article 25).

(IV) Further strengthening post-registration supervision and management requirements.

The circumstances for revocation of registration have been refined. It is explicitly stated that, “where registration is granted to an enterprise that lacks the requisite qualifications or does not meet the registration conditions”, it shall be revoked (Article 27). The scenarios for "non-acceptance of registration applications" have also been clarified. Specifically, where the General Administration of Customs has legally suspended the import of food products from a specific country (region), registration applications from relevant food enterprises in that country or region will not be accepted for the duration of the suspension (Article 28).

(V) Further optimizing registration management process.

Taking into account the practical regulatory circumstances of different countries (regions), the Regulations now accept "certificates issued" by overseas competent authorities as valid proof of enterprise identity (Item 2, Paragraph 1 under Article 9). Provisions for the automatic renewal of enterprise registration have been introduced, further streamlining the management measures for registration renewal (Article 21). The registration renewal procedures for enterprises have been improved by extending the application period from "3 - 6 months" to "3 - 12 months" before the expiration date, providing enterprises with adequate lead time (Article 22).

Pursuant to the Agreement on Technical Barriers to Trade and other relevant provisions, members are required to observe a reasonable interval, typically no less than six months, between the publication and implementation of new technical trade measures, unless concerning emergency actions. In line with this principle, the newly revised Regulations have therefore incorporated a sufficient transition period and are set to officially enter into force on June 1, 2026.