2021-67: Plant Export Operations –Update on new registration process for food processing and storage facilities handling product for export to China and product labelling requirements

3 December 2021

Purpose

This Industry Advice Notice (IAN) is to provide updated information on the registration of food processing and storage facilities handling product for export to China, and product labelling requirements for food products exported to China.

Key points

The advice in this notice updates information provided in previous notice IAN 2021-58.
The registration and labelling requirements for China do not apply to fresh fruit orchards, fresh fruit packhouses and fresh fruit storage facilities.
The registration and labelling requirements for China do not apply to unprocessed wheat and barley.
We have received informal advice that the General Administration of Customs of the People’s Republic of China (GACC) will enforce new labelling requirements for foods exported to China for products produced on or after 1 January 2022. This advice supersedes previous labelling information provided in IAN 2021-58.
We established a process for applications for facilities with existing trade in Article 7 products described in Section 1.4. This only applies to those facilities that did not submit their application by 5:00pm AEDST 29 October 2021 and can demonstrate a history of trade.
The GACC Single Window System is now available in English for products requiring self-registration as per Article 9 of Decree 248. Advice on self-registration is provided in Section 2.
Information about ‘China’s new requirements for imported food’ is published at Have Your Say China’s new requirements for imported food. This includes frequently asked questions and a recording of the department-led webinar held on 22 October 2021 and 25 November 2021.
China has published an English translation of the Registration and Administration of Overseas Producers of Imported Food (Decree 248).
China has not published an English translation of the Measures for the Administration of Imported and Exported Food Safety of the People’s Republic of China (Decree 249).

1 Food processing and storage facilities handling products for export to China that require departmental recommendation for registration with GACC (Article 7 food)

1.1 Submission of recommendations for registration with GACC received prior to 29 October 2021

We assessed and collated information provided in applications through the online service described in IAN 2021-58, and submitted our recommendations for registration to GACC on 29 October 2021.
Applications received after 5:00 pm AEDT 29 October 2021 were not included in the submission and as such, may encounter delays with registration and disruption to trade.
We understand GACC will use this information to publish approved lists of food processing and storage facilities on their website, however a specific timeframe has not yet been advised.

1.2 Process for amendments to applications to be determined

We will provide further advice to industry on how to apply for an amendment to an application.

1.3 Competent authority issued registration number

GACC requires that facilities have a competent authority issued registration number. To comply with this requirement, we provide your department establishment number (also referred to as an ER number).
For facilities with an existing department establishment number, we have provided this to GACC.
For facilities that do not have a department establishment number, we have allocated new numbers and these have been provided to GACC. We are in the process of notifying facilities of their numbers.
If a business has multiple facilities, a unique establishment number will be issued for each facility location.
Facility’s department establishment numbers have been provided to GACC for all food categories the facility handles for export to China that require departmental recommendation for registration in the submissions sent on 29 October 2021.

1.4 Application requirements for facilities with a history or trade to China due by 15 December 2021

Food processing and storage facilities handling Article 7 foods that have exported to China since 1 January 2017 and did not submit an application by 29 October 2021 should apply as soon as possible.
Applications will be accepted up until COB 15 December 2021.
We will submit these new recommendations for registration to GACC on 20 December 2021.
Facilities that have not submitted an application by this deadline may encounter delays with registration and disruption to trade when China’s requirements come into effect on 1 January 2022.
Note: GACC required Australia to submit its recommendations for registration by 31 October 2021 and has not been advised if submissions after this date will be accepted. Facilities included in the December 2021 submission may therefore not be accepted, resulting in delays with registration and disruption to trade when China’s requirements come into effect on 1 January 2022.

You should not apply if:
- you applied using the department’s online service in October 2021
- you applied using the department’s online service in October 2021 and need to amend your application. GACC has not advised of the process to amend applications so we cannot amend applications at this time
- products from your facility are new to being exported to China and you do not have a history of trade since 1 January 2017. Refer to Attachment 2 for more information
- you are a brand owner and use a contract manufacturer to process and store your products – confirm with your contract manufacturers if they need to apply
- you are an exporter and do not process or store any food – confirm with your suppliers if they need to apply
- you are a freight forwarder providing transitory storage only
- your facility only manufactures products that are on the Australian Register of Therapeutic Goods (ARTG)
- you are handling only Article 9 foods – refer to Section 2 for information on the self-registration process.
To apply, complete the application form ‘Export listing application for food processing and storage facilities handling product being exported to China’ provided at Attachment 1 and submit with documentary evidence of your food safety management system to exportlisting@aff.gov.au before COB 15 December 2021.
Acceptable documentary evidence of food safety management system includes:
- A state, territory or local council food business registration, licence, notification or accreditation number
- certification of third-party accredited food safety management system (for example, HACCP, BRC, SQF, Freshcare, ISO 22000, other)
- for edible grains (e.g. oats, sorghum, field peas and mung beans), nuts and seeds you can provide a copy of your department Registered Export Establishment certificate
- for facilities that manufacturer both therapeutic goods (i.e. on the ARTG) and nontherapeutic goods you can provide a copy of your Therapeutic Goods Administration (TGA) licence to manufacture.
Food processing facilities that carry out the final processing step or final storage before export to China need to be registered with GACC. Each physical facility (location) needs to be registered.
Applications must be submitted directly by the processing or storage facility. Exporters and brand owners, for example, cannot submit on the facility’s behalf. Applications should be submitted by a person in management and control role in the facility.
Further guidance on applying is provided at Attachment 2.

1.4 Labelling requirements

The food products must have a label on the inner packaging (smallest sale unit) and the outer packaging (transport packaging) with either the facility’s
- competent authority issued registration number (that is, your department establishment number)
  or
- GACC issued registration number.
  Note: GACC has not yet issued registration numbers.
The registration number can be affixed using a stick-on/adhesive label for all food products, except foods for special dietary uses and health foods.
Foods for special dietary uses and health foods must have the registration number printed on the smallest sales package and not affixed using a stick-on/adhesive label.
We recommend facilities start applying registration numbers to labels as soon as possible to avoid any potential clearance delays after 1 January 2022.
We have not received official guidance from GACC on whether the storage facility registration number also needs be displayed on exported food product labels.
We have also not received official guidance from GACC on the format or how the registration number should appear on product labels.

1.5 New applications for recommendation for registration with GACC

Guidance on the ongoing application process for Article 7 food has been published on the GACC Website. The guidance is only available in Chinese.
We are currently translating the documents; however, we understand that new application submissions for food processing and storage facilities will only be accepted after 1 January 2022.
We will issue further advice outlining the submission process once this is available.

2 Food processing and storage facilities handling product for export to China that require self-registration with GACC (Article 9 foods)

2.1 Self-registration through the Single Window System

Food processing and storage facilities that handle Article 9 foods for export to China must complete self-registration of their facilities through the GACC Single Window System.
The Single Window System is now available on the GACC website in Chinese and English.
GACC has released a Guidance Document for the Single Window System registration process in Chinese only.
We note the guidance outlines the process for issuing a GACC registration number to food facilities that apply through the Single Window System.
We recommend facilities self-register through the Single Window System as soon as possible before 1 January 2022.
Self-registration is based on the physical location of the facility. Each location needs to be registered separately.
Brand owners using contract manufacturers should not register, but ensure each contract manufacturer completes the self-registration process.
Contract manufacturers only need to self-register once.
Freight forwarders providing transitory storage services do not need to apply.
Refer to Attachment 3 for updated instructions on how to access the Single Window System and guidance for starting an application.
Note: The Single Window System is owned and administered by GACC and we do not have oversight of the information submitted.
The guidance in Attachment 3 is current to the version of the Single Window System available as at 29 November 2021 and may change. Facilities that commenced self-registration prior to 1 November 2021, are advised to complete their applications again as per advice in Attachment 3.
Facilities self-registering through the Single Window System should be aware of fraudulent websites that are charging excessive fees to assist with registration. GACC do not charge for the registration through the Single Window System.

2.2 Registration numbers for self-registration

We understand the Single Window System requires applicants to provide a ‘registration number approved by the competent authority of located country or region’.
We recommend using your facility’s department establishment number where possible.
If the facility does not have a department establishment number. we recommend using either
- the food business registration or notification number issued by a state, territory or local government
  or
- another unique identifying number for your business; for example, your Australian Business Number (ABN) or Australian Company Number (ACN).
Where the application requires the upload of a ‘production license certificate issued by the competent authority of the located country’, we recommend providing one of the following to meet this documentation requirement
- department issued Export Registration Certificate (where available)
- department issued Export Accredited Facility Certificate (where available)
- food business registration certificate issued by a state, territory or local government authority
- certificate of free sale
  or
- business licence.

2.3 Labelling requirements

All registered facilities of exported food products must label the inner packaging (sale unit containing the pre-packaged food of the individually saleable independent packaging) and outer packaging (transport packaging) with the
- competent authority issued registration number (that is, establishment, number, domestic government food business registration, ABN or ACN)
  or
- GACC issued registration number.
  Note: GACC has not yet issued registration numbers.
If using the ‘registration number approved by the competent authority of located country or region’ it must match the registration number that was used when completing the self-registration process in the Single Window System (refer Section 2.2).
The registration number can be printed on the packaging or affixed using a stick-on/adhesive label.
We have not received official guidance from GACC on whether the storage facility registration number also needs be displayed on exported food product labels.
We have also not received official guidance from GACC on the format or how the registration number should appear on product labels.

Background

Background information on this notice can be found in IAN 2021-41, IAN 2021-52, IAN 2021-53, IAN 2021-55 and IAN 2021-58.

Information about China’s new requirements for imported food is also published at Have Your Say China’s new requirements for imported food.

Attachments

Attachment 1 - Export Listing Form - China Imported Food Requirements - existing trade Article 7 XLSX [56 KB]
Attachment 2 - Guidance on applying to be registered for Article 7 products for export to China DOCX [123 KB]
Attachment 3 - Update to China registration and labelling DOCX [2.3 MB]

Contact information

Contact Export Listing for any enquiries.

Rossana Carr
A/g 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.