In accordance with “Supervision and Management Measures for the Inspection and Quarantine of Import and Export Feed and Feed Additives”, GENERAL ADMINISTRATION OF CUSTOMS, P.R.CHINA (GACC) shall conduct risk analysis of the countries or regions that export feed to China for the first time, and conduct retrospective review of the countries and regions that have already exported or are exporting feed to China. According to the results of risk analysis and retrospective review, GACC will adjust and publish the white list of countries and regions allowed to export feed and the permitted feed categories.
In addition, on this basis, GACC implement the registration system on the manufacturers of the countries or regions that allow to export feed to China. Only the feed from the registered manufacturers is allowed to export to China. For example, pet food is a kind of feed products, if the overseas manufacturer of the imported pet food has not approved by GACC, it cannot export their pet food to China.
White list of the approved countries/regions and the approved manufacturers of pet food
Talking about the white list of the approved countries/regions of pet food, until May 27, 2021, the latest list is “Countries and regions allowed to export feed and the permitted feed categories (not containing plant - derived feed materials) (20210319)”. According to this list, there are totally 19 countries/regions are allowed to export pet food to China, including Thailand, Taiwan, Philippines, Uzbekistan, Netherlands, France, Belgium, Germany, Denmark, Czech Republic, Italy, Austria, the United States, Canada, Brazil, Argentina, New Zealand, Spain and Australia. In other word, pet food from the above 19 countries/regions are allowed to export to China.
Talking about the white list of the approved manufacturers of pet food, up to May 27, 2021, a total of 199 pet food manufacturers in the 19 countries (regions) have completed the GACC manufacturer registration. Among them, the United States has the largest number of registered pet food manufacturers, with 51 companies in total, followed by Thailand with 33 companies. Figure 1 shows the number of registered overseas pet food manufacturers in specific countries/regions.
* For the moment, pet food produced by manufacturers in New Zealand is allowed to export to China without GACC manufacturer registration certificate.
At the same time, it should be noted that before registration, overseas pet food manufacturers should ensure that no raw materials involved in animal epidemic bans are used in their pet food. Companies can search for prohibited animal raw materials and their origin according to “List of animals and animal products prohibited from entering China because of the animal diseases in the countries/region”. GACC will adjust this list according to animal epidemic ban announcements, risk warning notices, and bilateral agreements, etc., adding new prohibited animals and their products and origins, or lifting restrictions on certain animals and their products.
The basic requirements for overseas manufacturer registration
Overseas feed manufacturers shall meet the relevant requirements of the laws, regulations and standards of the exporting country (region), and meet the equivalent requirements of the relevant Chinese laws, regulations and standards.
Step 1: Overseas manufacturer prepares the required documents according to the requirements of GACC, and submits the materials to competent authority of the exporting country/region.
Step 2: The competent authority submits the list of overseas manufacturer that plans to export feed, and forwards the application materials to GACC.
Step 3: GACC reviews the submitted materials, and send a questionnaire involving import risk analysis to the competent authority. Overseas manufacturer should assist relevant departments in responding to the questionnaire.
Step 4: GACC arrange experts to conduct the risk assessment after receiving the response. If necessary, supplement information will be requested by GACC.
Step 5: For those qualified manufacturers, after consultation with the competent authorities, GACC may send experts to the exporting country/region to conduct on-site inspections of their feed safety supervision system and conduct random checks on the manufacturer applying for registration.
Step 6: For the overseas manufacturers that meet the requirements or have not been spot-checked, GACC will permit the application and publish the latest list in the GACC official website.
Registration materials required
The required material varies according to the risk level of different feed products and countries, and generally includes:
- Manufacturer information: manufacturer name, address, and official approved code.
- Product information: product name, main ingredients, application scope, etc.
- Official certifying documents: prove that the recommended manufacturer has been approved by the competent authority, and its feed products is allowed to sell in the origin of countries/regions.
- Exporting countries/regions related laws, regulations and standards on animal epidemic prevention and control, veterinary hygiene management, veterinary drug residue control, and manufacturer registration management.
- Exporting countries/regions authorities’ organization settings, laboratory testing systems, and management and technical personnel deployment.
- Evaluation of the inspection and quarantine and veterinary hygiene control of the recommended manufacturer by the competent authorities of the exporting countries/regions.
- Other relevant materials.
Since the registration of overseas manufacturers requires the recommendation of the competent authority of the country/region where the manufacturer is located, the entire registration duration is uncontrollable, but usually cost about 6 to 12 months.
Validity of the registration
Five years. If the overseas manufacturer needs to extend the period of validity, the competent authority of the exporting country/region shall request the GACC to extend the period of validity 6 months prior to the expiry of the period of validity. If necessary, GACC may arrange experts to the exporting country /region to conduct the retrospective review of its feed safety supervision system, and conduct random inspections of overseas manufacturers that apply for extension. For other overseas manufacturers that meet the requirements or have not been spot-checked, the validity period of registration will be extended by 5 years.
- Confirm the pet food category
- Review if the fee raw material and feed additive used are allowed to use or not, meanwhile, review the use level
- If anything incorrect, provide the revision suggestions
- Confirm the pet food category
- Review the original label and Chinese label, and provide revision suggestions
- Design Chinese standard label
- As the agent register pet food with MARA
- Arrange sample clearance and sample test
GACC Registration Service of Overseas Manufacturer of Imported Feed and Pet Food
- Preliminary evaluation of the manufacturer
- Assist client in preparing and composing documents
- Guide the manufacturer to apply for registration through the competent authority