In April 2021, China’s General Administration of Customs (GACC) announced new legislation, Decree 248, which took effect on January 1, 2022, for food manufacturers, processors, and storage facilities exporting to China.  All overseas food manufacturers, processors, and storage facilities must be registered with the Chinese authorities to export to China.  Article 2 of Decree 248 exempts food additives from the Decree’s registration requirements.  Per China’s Food Safety Law, food additives are defined “artificial and natural substances added to food for the purpose of improving the quality, color, aroma, and taste of food ….” This means that flavoring ingredients and compounded flavors as well as other types of food additives exported to China are exempt from the registration requirements.

The US FDA recently issued a constituent update describing a voluntary facility information collection process for exporting food products contained within categories 8-18 as listed in Article 7 of the decree.  The USDA has published a GAIN report with a translation of Decree 248, and the FAS (Foreign Agricultural Service) has provided a separate report including a list of the harmonized tariff codes the represent the scope of commodities subject to the Decree 248 requirements.

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Posted on 12 January 2022