6. Registration Processes

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6. Registration Processes

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Beers, RTDs, Whisky
China

This section provides information on any product notification or registration and manufacturing site registration processes.

6.1 Product Notification

According to the “Food Safety Law of the People’s Republic of China” [1], only special food needs to be notified before placing on the market.

General Foods

General Foods does not need to be notified before being placed on the Chinese market. It is the responsibility of the business operator to ensure the product complies with Chinese regulations and standards.

Category

Alcoholic drinks

Same as General Foods above.

Product

Beer

Same as General Foods above.

Ready-to-drink beverages (mainly Chuhai)

Same as General Foods above.

Whisky

Same as General Foods above.

6.2 Product Registration

According to the “Food Safety Law of the People’s Republic of China” [1], only special food needs to be registered before launch.

General Foods

General foods do not need to be registered before being placed on the Chinese market. It is the responsibility of the business operator to ensure the product complies with Chinese regulations and standards.

Category

Alcoholic drinks

Same as General Foods above.

Product

Beer

Same as "Category" (alcoholic drinks) above.

Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above.

Whisky

Same as "Category" (alcoholic drinks) above.

6.3 Other Notes or Requirements

Product Notification

N/A

Product Registration

N/A

6.4 Manufacturing Site Registration

According to the “Measures of the People's Republic of China for the Administration of Import and Export Food Safety” [2] and “Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food” [3], all overseas food manufacturers must register with GACC before importation.

General Foods

According to “Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food” [3], there are 18 food categories that shall be recommended by the competent authorities from the country (region) of origin. Of the 18 food categories, 17 are General Foods: meat and meat products, casings, aquatic products, dairy products, bird’s nest, and bird’s nest products, bee products, eggs and egg products, edibles fats and oils, stuffed pasta, edible grains, grain milling industrial products and malt, fresh and dehydrated vegetables as well as dried beans, seasonings, nuts and seeds, dried fruits, unroasted coffee beans and cocoa beans, foods for special dietary uses.

Manufacturers of other food categories shall do the registration by themselves or through a 3rd-party agency.

The registration of overseas production enterprises of imported foods is valid for 5 years. Enterprises that have been approved for registration shall label the registration number in China or the registration number approved by the competent authority in the country (region) where they are located on the inner and outer packaging of the foods exported to China.

The overseas food manufacturers' GACC registration portal link (the optional language is Chinese or English): https://cifer.singlewindow.cn/

Category

Alcoholic drinks

This category belongs to the self-registration category. The overseas manufacturers should apply themselves for the registration or through a 3rd-party agency. The registration documentation checklist includes:

Enterprise's application for registration, please refer to Attachment 10-Enterprise's application for registration-Template-EN [4]. (unofficial translation, only for reference)
Enterprise identification documents, e.g. business licenses issued by the competent authority in the country (region) where the enterprise is located.
A statement indicating that such recommended enterprise meets the requirements of these regulations. Please refer to Attachment 11 [4] -Enterprise Compliance Statement-Template-EN. (unofficial translation, only for reference)
The enterprise food safety, health, and protection system documents, e.g. the floor plan of the enterprise's plant area, workshop, and refrigeration house, as well as process flow charts and so on.

The registration documents can be in Chinese or English. The general registration process for self-application is as follows:

Product

Beer

Same as "Category" (alcoholic drinks) above.

Ready-to-drink beverages (mainly Chuhai)

Same as "Category" above.

Whisky

Same as "Category" above.

6.4.1 Standard/Rules for Manufacturing Site

General Foods

According to “Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food” [3], The General Administration of Customs shall, on its own or by entrusting relevant agencies, organize a review team to conduct evaluation and review to overseas production enterprises of imported food applying for registration through written inspections, video inspections, on-site inspections, etc., and combinations thereof.

The General Administration of Customs shall, based on the evaluation and review, approve the registration, offer the registration number in China, and notify the overseas production enterprise of imported foods or the competent authority in the country (region) where it is located in written form for those meeting the registration requirements; for those rejected for registration, the General Administration of Customs shall notify the overseas production enterprise of imported foods or the competent authority in the country (region) where it is located in written form.

For the inspection points of the 18 food categories that shall be recommended by the competent authorities in the country (region), please refer to the GACC Guideline on Registration of overseas producers of imported food: http://online.customs.gov.cn/static/pages/treeGuide.html

There are no mandatory inspection points for the other self-registration food categories. Therefore, according to “Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food” [3], the food safety management system of the country (region) where the enterprise is located shall be subject to the equivalence evaluation and review of the General Administration of Customs. Therefore, the customs will conduct the evaluation and the manufacturing site inspection based on the equivalence evaluation and review agreement.

Category

Alcoholic drinks

Because the category “Alcoholic drinks” is categorized as self-registration, and according to “Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food” [3], the food safety management system of the country (region) where the enterprise is located shall be subject to the equivalence evaluation and review of the General Administration of Customs. Therefore, the customs will conduct the evaluation and the manufacturing site inspection based on the equivalence evaluation and review agreement.

Product

Beer

The overseas food manufacturers' registration is only based on the food category. All the products should be provided under the food category while applying to register.

Ready-to-drink beverages (mainly Chuhai)

Same as "Beer" above.

Whisky

Same as "Beer" above.

6.4.2 Other Notes or Requirements for Manufacturing Site Registration

General Foods

The list of approved overseas manufacturers of imported food can be searched at https://ciferquery.singlewindow.cn/.

Please make sure the manufacturer registration information is already published before importation.

Category

Alcoholic drinks

Same as General Foods above.

Product

Beer

Same as General Foods above.

Ready-to-drink beverages (mainly Chuhai)

Same as General Foods above.

Whisky

In addition to the General Foods and alcoholic drinks requirements, the below applies.

According to the Quality requirements for spirits - Part 1: Whisky (draft for approval) [5] (please note that only the final officially released version shall be considered for implementation), the requirements for the production process include:

Raw materials such as grains and water should comply with corresponding standards and requirements.
The maximum alcohol content of new whisky should be less than 95% vol.
Single malt whisky should not use exogenous enzymes during production and should be distilled 2 to 3 times in copper pot stills. The original whisky should be aged in oak barrels for no less than 3 years. Single malt whisky should not use oak chips, oak shavings, or other oak products.
The original whisky should be aged in wooden barrels for no less than 2 years; only grain whisky can use oak chips.
The volume of the wooden barrels used for aging whisky should not exceed 700 L.
Edible alcohol, coloring substances (except caramel color), and flavoring substances (except for flavored whisky) should not be used in the production of whisky.