New Regulatory Obligations on Exporting Colostrum, Raw Milk and Dairy Products into China

On 1st  Jan 2013,  The Administrative Measures on Inspection and Quarantine of Export-import Dairy Products(AQSIQ Decree No. 152) were issued by The General Administration of Quality Supervision, Inspection and Quarantine of People’s Republic of China on 1 January 2013. This Decree will come into force on 1 May 2013. Colostrum, milk and dairy products will be regulated under this Decree when they are imported into and exported from China. The manufacturers, distributors and importers are required to comply with specific obligations under this Decree.

Definition of Colostrum, Milk and Dairy Products under this Decree

Colostrum: is defined as a yellowish liquid, especially rich in immune factors, secreted by the mammary gland of female mammals within 7 days after the birth.
Raw Milk: is defined as a yellowish liquid, secreted by the mammary gland of female mammals, without any variation of natural compositions. Colostrum, milk secreted during the period of antibiotic application and withdrawal, and denatured milk cannot be considered as Raw Milk.
Dairy Products: are defined as any of the foods made from colostrum and raw milk, including pasteurized milk, sterilized milk, modulation milk, fermented milk, cheese and processed cheese, cream, butter, anhydrous butter, condensed milk, milk powder, whey powder, whey protein powder and milk-based infant formula and so on.

Highlights of AQSIQ Decree 152

Oversea manufacturers are required to go through a registration process under AQSIQ, when their products - Colostrum, raw milk and dairy products - are being exported into China. The specific regulation on how to do registration is still under discussion and has not been published yet. Oversea manufacturers can continue exporting until the publication of this specific regulation.

The Health Certificates, which have been issued by the governments of exporting countries, need to be provided to the AQSIQ, when these products – colostrums, raw milk and dairy products – are being imported into China. The templates of Health Certificates of below countries have been reviewed and published on AQSIQ’s website. The Colostrum, raw milk and dairy products from below countries are allowed to be imported into China.

Spain, Switzerland, South Korea, Malaysia, Chile, Finland, Ireland, Austria, Canada, Greece, the Netherlands, Argentina, Thailand, Sweden, Belarus, Belgium, Uruguay, Czech, Singapore, Italy, France, New Zealand, United States, Germany, Denmark, Brazil, Poland, Australia, United Kingdom
Chinese importers need to register themselves in AQSIQ’s system when they are planning to import Colostrum, raw milk and dairy product into China. These companies should be the domestic legal entities, who are directly importing those products into China. The duration of notification process will be 10 working days.

Besides, Chinese importers are required to apply for Quarantine Permit of Entry Animal and Plant.

  • Raw Milk
  • Dairy products made from raw milk and proceeded without any heat sterilizations
  • Pasteurized milk


The duration of application process will be 20 work days and the permit has the validity of 6 months.

Companies (exporters or importers) are required to provide comprehensive testing reports according to the specific national standards for food safety when the products are imported into China for the first time. For subsequent imports, a copy of the test report of first import and regular testing reports need to be provided.

Chinese importers are required to provide original label, translation of original label and Chinese label of their products. The Chinese label should meet the requirements of below national standards:

  • General standard for the labeling of prepackaged foods [GB 7718-2011]
  • General standard for the nutrition labeling of prepackaged foods [GB 28050-2011]

Find our expert

Mr David Wan, Team Leader, Food & Health Products, CIRS China
11F Dongguan Building, 288 Qiuyi Road, Binjiang District, Hangzhou, China, 310052
Tel: +86-571 8720 6555 | Fax: +86-571 8720 6533