Exporting Food to China: GACC CIFER Registration, Decree 280, Labels
Overseas factories that make food for China, and cold stores holding animal-origin or aquatic foods, must be registered with China Customs (GACC) in its CIFER system; since 1 June 2026 the rules are in GACC Decree 280, which replaced Decree 248. The Chinese importer and the overseas exporter must also be on file with customs, and prepackaged food needs a Chinese label that meets Chinese standards before it can enter.
Checked against official sources: 2026-09
At a glance
Decree 280 replaced Decree 248 on 1 June 2026
GACC issued Decree 280, the Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food, on 14 October 2025. It took effect on 1 June 2026 and repealed Decree 248, which had applied since 2022. It covers overseas firms that produce, process or store food for China, but not makers of food additives or food-related products such as packaging. Primary agricultural products follow a separate GACC announcement (2025 No. 219), and cross-border e-commerce retail imports are left to separate rules.
Registrations made under Decree 248 remain valid, and no new application is needed. What changed:
- A catalogue of 17 food categories that need an official recommendation, set by risk and open to updates, replaced Decree 248's fixed list of 18 categories.
- Registration is valid for 5 years and renews automatically for another 5 years, except for meat and meat products and bird's nest products, or where the firm is under rectification or imports from its country are suspended. Those that cannot renew automatically apply 3 to 12 months before expiry.
- The China registration number, or the number approved by your country's authority, must be marked on the food packaging, instead of on both the inner and outer packaging.
- A new list registration route lets an exporting country's authority register its manufacturers as a list, where GACC recognises that country's food safety system under a bilateral arrangement.
Which route applies: official recommendation or self-application
The official recommendation catalogue (GACC Announcement 2026 No. 27) covers 17 categories: meat and meat products, casings, bird's nests and bird's nest products, bee products, eggs and egg products, edible oils and fats, stuffed pastry products, edible grains, grain milling products and malt, dehydrated vegetables, seasoning powders, nuts and seeds, dried fruits, foods for special dietary uses, health foods, dairy products and aquatic products.
All routes run through CIFER at cifer.singlewindow.cn. GACC charges no registration fee and tells applicants to make sure they are using the genuine system, not a fake website.
- Official recommendation (catalogue foods): your country's competent authority audits the plant and issues a recommendation letter (in Australia, for example, the Department of Agriculture, Fisheries and Forestry). The manufacturer then submits the application to GACC in CIFER, itself or through an authorised agent.
- Self-application (all other foods): the manufacturer applies directly in CIFER and must confirm a set of mandatory compliance declarations.
- List registration: only where GACC has recognised the exporting country's system under a bilateral arrangement; the authority submits a list of manufacturers.
- Cold stores that hold food of land-animal origin or aquatic products must also register.
- Check the category with CIFER's product category query, which works by HS code. The catalogue differs from Decree 248's list, so check again for any new plant or product.
- Goods from an officially recommended plant can still be imported if made while its registration was valid and still within shelf life. For a self-registered plant, the registration must be valid when the goods are declared.
Importer and exporter filing, certificates and inspection
Under GACC Decree 249 (Administrative Measures on Import and Export Food Safety, in force since 1 January 2022), the overseas exporter or its agent files with GACC and the Chinese importer files with customs where it is based (Article 19). Since 5 September 2024 the exporter gets an 18-digit code and the importer uses its unified social credit code; both go in the import declaration (licence codes 508 and 509). The importer must also review its overseas suppliers' food safety controls (Article 22), so expect questions.
Customs clears food through conformity assessment, which can include evaluating the exporting country's food safety system, manufacturer registration, importer and exporter filing, quarantine approval, checks of accompanying certificates, document review, on-site inspection and sampling (Article 10). GACC may evaluate a country's system before it first exports a type of food (Articles 11 and 12), so ask your competent authority whether China accepts your product from your country and which official certificate it needs.
Certificates depend on the product and the country. Dairy, for example, needs a health certificate issued by the exporting country's authority, signed, stamped and naming China as the destination. On arrival the food is kept at a place customs designates or approves (Article 31). Food that passes is released; food that fails gets a certificate of non-conformity and must be destroyed or returned if it is unsafe, while other failures may be corrected by technical treatment and re-checked (Article 33).
Chinese labels: GB 7718, GB 28050 and the 2027 changes
Packaging and labels of imported food must meet Chinese laws and national food safety standards (Decree 249, Article 30). Prepackaged food needs a Chinese label, printed or stuck on. The importer must check it before import, food with a non-compliant label may not be imported, and customs checks labels as part of inspection; if the goods are picked for inspection, the importer shows the original label, its translation and the Chinese label sample (GACC Announcement 2019 No. 70).
Health foods and foods for special dietary uses must have the Chinese label printed on the smallest sales package, not stuck on, and infant formula must have it printed before import. Fresh and frozen meat and aquatic products need specific marks in Chinese and English (or Chinese and the exporting country's language) on inner and outer packaging.
NHC and SAMR published GB 7718-2025 (labelling) and GB 28050-2025 (nutrition labelling) in March 2025. They apply from 16 March 2027 and make allergen labelling mandatory, require the expiry date, and allow digital labels such as QR codes in addition to the printed label. Ingredients and additives must also meet Chinese standards, such as GB 2760-2024 for food additives, in force since 8 February 2025.
- Name of the food, ingredient list and net content
- Country of origin, and the name, address and contact details of the agent, importer or distributor in China
- Production date and shelf life; from 16 March 2027, the production date and expiry date in year, month, day order
- Storage conditions, and a nutrition label under GB 28050
- Standard Chinese characters; other languages may be added
- Allergens, mandatory from 16 March 2027 for eight groups: cereals containing gluten, crustaceans, fish, eggs, peanuts, soybeans, milk and tree nuts
- The manufacturer's registration number on the food packaging (Decree 280, Article 14)
Health foods, infant formula and special foods
Some products also need approval of the product itself from the State Administration for Market Regulation (SAMR) before import. Health foods imported for the first time must be registered with SAMR, except vitamin and mineral supplements, which are filed instead. Infant formula, including liquid formula since 1 December 2025, must have its formula registered with SAMR before it can be shipped, and other special foods such as foods for special medical purposes also need product registration.
Health foods and foods for special dietary uses are also in GACC's official recommendation catalogue, so the plant needs the recommendation route as well.
Cross-border e-commerce (CBEC) retail imports
Food sold to Chinese consumers through cross-border e-commerce platforms is regulated as goods for personal use and is typically not subject to licensing, registration or record filing. Decree 280 leaves CBEC retail imports to separate rules, and Australia's agriculture department confirms that CBEC exports do not need CIFER registration.
Products must be on China's CBEC positive list, a consumer may spend up to RMB 5,000 per order and RMB 26,000 per year, and Chinese labels do not have to be fixed to the product. Selling to a Chinese importer in ordinary trade needs the full registration, filing and labelling rules.
Rules change. Confirm current requirements with your country's competent authority, your Chinese importer and GACC's CIFER system before you ship.
Step by step
- Find the HS code with Triplicate's HS code lookup, then check in CIFER's product category query whether your food needs an official recommendation or self-application.
- Ask your country's competent authority whether China accepts the product from your country and which official certificate, if any, each shipment needs.
- Register each factory, and any cold store holding animal-origin or aquatic foods, in CIFER at cifer.singlewindow.cn; for catalogue foods, get the authority's audit and recommendation letter first.
- For health foods, infant formula or foods for special medical purposes, complete SAMR registration or filing before the first shipment.
- Have the Chinese importer file with its local customs, and file as overseas exporter with GACC, yourself or through an agent, to get the 18-digit code.
- Agree the Chinese label with the importer before printing: GB 7718 and GB 28050 content, importer details, origin and the registration number on the packaging. Plan for the 2025 versions that apply from 16 March 2027.
- Send the importer a matching invoice and packing list (Triplicate's free generator makes both), the transport document and any certificates, so it can declare the registration number (licence code 519), the purpose as food (食用) and both filing codes.
- Track expiry dates: meat and bird's nest plants apply for renewal 3 to 12 months before expiry; other registrations renew automatically unless GACC excludes them.
Documents you usually need
- Commercial invoice and packing list
- Bill of lading or air waybill
- Manufacturer's China registration number (on the packaging and in the declaration)
- Overseas exporter's 18-digit GACC filing code and the importer's unified social credit code
- Official health or sanitary certificate from the exporting country, where the product needs one (e.g. dairy)
- SAMR registration or filing for health foods, infant formula and other special foods
- Chinese label, plus the original label and its translation if customs inspects the goods
Common problems and how to avoid them
What to do: Check the number and its validity in CIFER before shipping, and give it to the importer for the declaration (licence code 519).
What to do: Agree the label with the importer before printing; print health food and special dietary food labels on the smallest sales package.
What to do: Complete both filings before the first shipment and give the importer your 18-digit exporter code.
What to do: These do not renew automatically; apply 3 to 12 months before expiry.
What to do: GACC charges no fee; use only cifer.singlewindow.cn and check any agent's authorisation.
What to do: Check market access and certificate requirements with your competent authority before signing a sales contract.
Sources
- GACC Decree No. 280: Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food (in Chinese) General Administration of Customs of China (State Council Gazette, gov.cn)
- GACC Announcement 2026 No. 27 on implementing Decree 280: catalogue, renewal, declaration (in Chinese) General Administration of Customs of China (gov.cn)
- GACC Decree No. 249: Administrative Measures on Import and Export Food Safety (in Chinese) General Administration of Customs of China (State Council Gazette, gov.cn)
- GACC Announcement 2024 No. 105 on importer and exporter filing for imported food (in Chinese) General Administration of Customs of China (via Fujian Provincial Department of Commerce)
- GACC Announcement 2019 No. 70 on label inspection of imported and exported prepackaged food (in Chinese) General Administration of Customs of China (gov.cn)
- Measures for the Registration and Filing of Health Foods (in Chinese) State Administration for Market Regulation (gov.cn)
- China: GACC Issues Decree 280 Implementation Guidance (CH2026-0034) USDA Foreign Agricultural Service (GAIN)
- China: FAIRS Country Report Annual 2026 (CH2026-0026) USDA Foreign Agricultural Service (GAIN)
- China: Prepackaged Food Labeling Standards Finalized, GB 7718-2025 and GB 28050-2025 (CH2025-0070) USDA Foreign Agricultural Service (GAIN)
- Industry Advice Notice 2026-28: GACC Decree 280, update to overseas enterprise registration requirements Department of Agriculture, Fisheries and Forestry, Australia
Rules change often. This note is practical guidance based on the sources above, not legal advice. Confirm current requirements with the authority, your importer or a licensed customs broker before you ship.
Trade notes
Common questions
We registered under Decree 248. Do we need to register again?
No. Registrations made under Decree 248 remain valid. At expiry most renew automatically for 5 years, but plants making meat and meat products or bird's nest products must apply 3 to 12 months before expiry. Mark the registration number on the food packaging.
Which foods need an official recommendation from our government?
Only foods in GACC's 17-category catalogue, including meat, dairy, aquatic products, eggs, edible oils, grains, nuts and seeds, dried fruits, seasoning powders, special dietary foods and health foods. Makers of other foods self-register in CIFER. Check your product by HS code in CIFER.
Can we use a Chinese sticker label?
For most prepackaged food, yes: the Chinese label may be printed or stuck on, but it must comply when the goods are imported. Health foods and foods for special dietary uses must have it printed on the smallest sales package, and infant formula labels must be printed before import.
Do cross-border e-commerce sales need GACC registration?
Generally no. CBEC retail imports are regulated as personal-use goods and are typically exempt from registration and filing, within the positive list and spending limits. Selling through a Chinese importer in ordinary trade needs the full registration, filing and labelling rules.
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