14 October 2021
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Purpose
Further to IAN 2021-52, we are providing detailed instructions for the registration of food processing and storage facilities handling product for export to China, and product labelling requirements for food products exported to China.
Australian food and storage facilities with a history of handling food exported to China from 1 January 2017, should read the information below and take appropriate action as required by specified timeframes.
Key points
- Further to IAN 2021-52, we have implemented an online service for facilities to apply for recommendation for registration with General Administration of Customs of the People’s Republic of China (GACC).
- Food and storage establishments that have been exporting to China since 1 January 2017 should read the information below to determine if they need to take action.
- The deadline for applications is 5:00pm, 22 October 2021.
- We do not have clear guidance from GACC regarding fresh fruit packhouses and storage facilities, so we recommend you prepare for self-registration from 1 November 2021.
- We understand from the description provided by GACC that Decree 248 is not applicable to unprocessed wheat and barley. However, this has not been confirmed definitively by GACC.
- The information for food establishments and storage facilities requiring self-registration with GACC in IAN 2021-52 has been updated with advice from GACC not to complete this process until after 1 November 2021.
1. Food processing and storage facilities handling products for export to China that require department recommendation for registration with China
- This applies to food processing facilities that carry out the final processing step for the following food categories, as well as storage facilities where product is subsequently handled prior to export to China. Detailed descriptions available in Attachment 1.
- Casings, eggs and egg products, bee products, edible fats and oils, stuffed wheaten food, edible grains, milled grain products and malt, fresh-kept/preserved and dehydrated vegetables and dry beans, condiments and seasonings, nuts and seeds, dry fruits, unroasted coffee and cocoa beans, food for special dietary uses, health foods.
- GACC has provided us with a list of products that have been identified as having historical trade since 1 January 2017. This list is included at Attachment 2.
- If your facility is handling a product for export to China that is not captured in this list, email Export Standards by 22 October 2021.
1.1 Applications required by 22 October 2021
- Food processing and storage facilities handling these products for export to China need to submit applications by 5:00 pm 22 October 2021 for us to be able to recommend registration with GACC in line with the new requirements.
- Late submissions may encounter delays in registration and could disrupt trade.
- We have established an online service for this application process. Food processing and storage facilities must complete and submit an application in order for us to recommend their registration with GACC. Guidance on how to apply is at Attachment 3.
- If you cannot access the online service, email Export Listing and request a form be sent to you.
- All food processing and storage facilities handling food listed in Attachment 1 must be registered with China for all food categories they handle. For example, should your facility handle ‘stuffed wheaten food’ and ‘fresh-kept/preserved and dehydrated vegetables and dry beans’ for export to China, your application must include each applicable food category. Further, if your food processing and storage facility has multiple locations, all must be registered individually.
- Once a facility has completed the online application, we will issue a number to those facilities that do not already have an existing departmental Establishment Number (also referred to as an ER number).
- For food processing and storage facilities handling multiple products for export to China, your facility will be issued a single establishment number. This number must be used for all products the food processing and storage facility handles for export to China. If your business has multiple facilities, a unique establishment number will be issued for each facility (location).
- For food processing and storage facilities that already have an existing departmental Establishment/ER Number, your existing number is to be used for newly registered products handled by your facility for export to China. You will be required to enter this number when completing the online registration process. For example, if a facility with an existing establishment number ‘000’ exports both meat and casings products to China. The existing ER number ‘000’ will be used in this case for the new casings registration.
1.2 Labelling requirements
- Labels must be affixed to both the inner and outer packaging for all products listed above, with the exception of foods for special dietary uses and health foods. For these products, adhesive product labels will not be accepted and labels must be printed on packaging.
- GACC’s new requirements specify that exported food must include on the inner and outer packaging, either a GACC-issued registration number or the registration number issued by the exporting country (departmental Establishment/ER Number). We understand that this also includes sales packaging.
- We will provide further advice on how facilities can meet this requirement following the issuing of numbers after applications are processed.
2. Food processing and storage facilities handling product for export to China that require self-registration with GACC
- Food processing and storage facilities for all foods that are not listed in Attachment 1 of this notice need to self-register or register through their importer or agent.
- As an amendment to IAN 2021-52, we understand that although the GACC established ‘single window service system’ is currently open for use, GACC has since advised that establishments requiring self-registration should not complete this process until after 1 November 2021.
- For establishments that have already completed registration through the ‘single window service system’, we are currently seeking advice from GACC on whether the registration process will need to be completed again following 1 November 2021.
- Revised instructions on how to complete this process will be provided to establishments in early November 2021.
- We do not have clear guidance from GACC regarding fresh fruit packhouses and storage facilities, so we recommend you prepare for self-registration from 1 November 2021.
Background
- Background information on this notice can be found in IAN 2021-41 and IAN 2021-52 The department has received correspondence from GACC regarding implementation of Decree 248.
- We have developed an online service to collect information from industry and have it collated and provided to GACC for registration before the deadline.
- A summary of the Decree may be obtained from the United States Department of Agriculture, Global Agricultural Information Network reports China: Regulations on the Registration and Administration of Overseas Producers of Imported Food - Decree 248.
Contact information
Contact Export Listing for any enquiries about using the our online service or China’s self-service window
David Ironside
Assistant Secretary
Plant Export Operations Branch
The information provided in this advice is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive. The Commonwealth endeavours to keep information current and accurate; however, it may be subject to change without notice. Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.