2022-21: China: Have you applied to renew your CIFER registration for your establishment? New requirements for fish and fish products to be exported to China

Date of issue: 14 December 2022
Date of effect:  31 December 2022
Reference Number: MAA2022- 21

Attention

• Industries—Industry bodies – Seafood Export Consultative Committee
• Export seafood establishments
• Exporters                                                                 
• Department of Agriculture, Fisheries and Forestry — Central and Regional offices

Purpose

This Market Access Advice (MAA) is for export registered vessels and land-based establishments that catch, process, manufacture, pack or store aquatic products that are intended for export to China. It will provide you with an update of the progress of the CIFER registrations by China and the impact of registrations not being renewed beyond 31 December 2022.

If you are currently seeking to extend your China Import Food Enterprise Register (CIFER) system registration and have not had confirmation that your registration has been renewed past 31 December 2022, please read the below information.

Background

For background, please see MAA 2022-11 at 2022-11: China: Fish: – Do you catch, store or prepare fish or fish products that are exported to China? China Import Food Enterprise Registration System and MAA 2022-13 at 2022-13: Do you need to update your establishments details in CIFER? New requirements for fish and fish products to be exported to China.
To subscribe to further updates, see: Market Access Advice Notices for Fish and Fish Products

The department is aware that despite best efforts to have applications submitted within CIFER, within the allocated period, a number of establishments have not had their registration updated and renewed. Because of these delays in the assessment of applications, establishments will need to consider the commercial risks associated with trading as the listing expiry date of 31 December approaches and renewals have not been approved.

For establishments that have confirmation that their extension application has been approved:

1. Establishments that have had their extension application approved should be showing a new expiry date for their CIFER aquatic products registration of 31 December 2027.
2. Trade should not be disrupted for these establishments as their registrations have now been renewed.

For establishments that have unapproved modification or extension applications in CIFER or are yet to submit them:

1. Establishments that have not submitted the necessary applications or have pending applications with no final decision received, need to consider the commercial risk associated with continuing to trade beyond 31 December 2022.
2. For establishments that can submit their extension application and have yet to do so noting:
   1. An approved modification application will not grant the establishment an extension of their current listing
   2. If establishments can, they are strongly encouraged to submit their extension applications now
3. Consignments exported or sourced from establishments that have not had their registration (listing) renewed before 31 December are at risk of having product detained at the port of entry into China if they are not cleared before 1 January 2023.
4. Establishments and exporters must consider the commercial risk involved in exporting over this period whilst applications remain pending with GACC. 

Departments actions to resolve this issue:

1. The department continues to monitor CIFER and engage GACC to advance Australian applications for establishments with a listing expiry date of 31 December.
2. The department is contacting establishments when movement is seen in their applications, identifying next steps where applicable.
3. The department has sought and continues to seek advice from China on whether product produced before 31 December is eligible for export or whether 31 December is a hard date for the clearance of product within China.
4. The department has provided a list of all establishments seeking China listing and has requested consideration of this list in the clearance of product after 31 December (we have not received a response to this request at the time of writing).

This MAA has been prepared using information available at the time of publication. The information in this MAA is current at the date of publication but may change in the future.
Please ensure that you regularly access the departments website at: Market Access Advice Notices 2022. You can subscribe to receive Market Access Advice Notices via our email notification system. You may change or cancel your subscription at any time.