The Chinese Labels for Imported Health Foods and Special Dietary Foods are Intended to be Directly Printed on the Package

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On June 12, 2020, the General Administration of Customs of the People's Republic of China (GACC) issued the "Administrative Measures on Import and Export Food Safety (Draft for Comment)" (hereinafter referred to as "Administrative Measures"), which is open to the public for comments. The deadline for public comments is July 11, 2020.

The "Administrative Measures" includes the inspection and quarantine requirements for import and export of meat, aquatic products, dairy products and other products. Therefore, after the official version of the regulation is released, the current "Administrative Measures on Import and Export Food Safety" (implemented on March 1, 2012), "Administrative Measures on Inspection and Quarantine of Imported and Exported Meat Products", "Administrative Measures on Inspection and Quarantine of Imported and Exported Aquatic Products" etc. will be abolished.

The important provisions related to imported food in "Administrative Measures" are as following:

1. The Chinese labels of imported health foods and special dietary foods must be printed directly

Article 38 of the "Administrative Measures" stipulates that: Chinese labels for imported health foods and special dietary foods must be printed on the smallest sales package.

CIRS Comments: At present, only the Chinese labels for imported infant formula milk powder must be printed directly on the smallest sales package before importing. The "Administrative Measures" proposes to extend this labelling requirement to health foods and all special dietary foods (including: infant formula foods, infant complementary foods, foods for special medical purpose (FSMP), complementary food nutrition supplementary foods, sports nutrition foods, nutrition supplementary food for pregnant women and wet nurse). At present, most enterprises generally prefer to use Chinese stickers (the Chinese label affixed to the package) for these products. After the implementation of the "Administrative Measures", they need to reprint the label information on the package, and the importers also need to be stricter in reviewing these labels.

2. Implement pre-inspection on imported food to improve customs clearance efficiency

Article 27 of the "Administrative Measures" stipulates that: upon the application of the food importer or agent, the customs may conduct pre-inspection on imported food, which could facilitate the clearance for them that have passed the pre-inspection. The scope, procedures and requirements for pre-inspection of imported food shall be formulated and published by the GACC.

CIRS Comments: The food pre-inspection model has been implemented in some local ports. The "Administrative Measures" intends to extend this convenience measure to all the ports. For foods that fail pre-inspection, enterprises can make rectification or take measures to stop loss in advance. For foods that pass pre-inspection, the customs will provide customs clearance convenience.

3. The GACC is responsible for formulating the annual imported food safety supervision and casual inspection plan

Articles 35 and 36 of the "Administrative Measures" stipulate that: the GACC shall formulate the annual imported food safety supervision and casual inspection plan. The customs will conduct inspection on imported food in accordance with the inspection plan.

CIRS Comments: If the inspection plan is disclosed to the public, the relevant enterprises can pre-inspect their products in accordance with the plan before importing. The risk of food being returned or destroyed will be effectively reduced.

Official Link:

Notice of "Administrative Measures on Import and Export Food Safety" for Comments