According to the updates, China is abandoning a fixed list of product categories and moving to a registration system based on risk assessment, taking into account the exporting country, specific enterprise, and type of product. Importers will now be assigned a risk level based on the type of product, which will affect registration methods, documentation requirements, assessment processes, and enterprise inspections.
The registration period for foreign manufacturers remains unchanged at five years, with the possibility of automatic renewal for a similar period, except in certain cases:
- if the product is on the list of exceptions where renewal is not possible;
- if the enterprise is working to rectify non-compliance issues caused by violations of requirements;
- in the event of a suspension of imports of the relevant food products.
The time frame during which companies can apply for registration renewal has also changed. It is now possible to apply three to twelve months before the current term expires.
Furthermore, the new procedure involves the creation of a product catalog for which official approval from the relevant authority of the exporting country is required for registration. After risk assessment or in the presence of new data on the safety of imported goods, the General Administration of Customs of China will be able to review the registration management requirements.
For countries with recognized food safety assurance systems, the registration mechanism through lists approved by competent authorities will continue to apply.
