Understanding China’s New GACC Registration Framework for Overseas Food Manufacturers

China’s registration framework for overseas food manufacturers is governed by GACC Decree No. 280, effective June 1, 2026, which replaces Decree No. 248. GACC registration in China generally applies to overseas enterprises involved in the production, processing or storage of food exported to China, with a few exceptions. The framework follows a risk-based approach. Manufacturers of food categories listed in the Catalogue of Imported Food Requiring Official Recommendation for Registration must additionally obtain recommendation from the competent authority of the exporting country or region, while manufacturers of other food categories may apply directly to GACC or through an authorized agent.

China has updated its framework of GACC registration for overseas food manufacturers. GACC Announcement No. 27 of 2026, issued on March 18, 2026, provides clarification on registration categories, renewal, storage facilities, and import declarations under the revised framework. The changes take effect alongside GACC Decree No. 280 from June 1, 2026.

For overseas food manufacturers supplying products to China, the key changes are summarized below.

Key Changes to GACC Registration in China

Fewer Food Categories Require Official Recommendation

The Catalog of Imported Food Requiring Official Recommendation for Registration has been reduced from 18 to 17 categories.

Among the changes, unroasted coffee beans and cocoa beans have been removed from the catalog. Certain categories covering oilseeds, miscellaneous grains, fresh vegetables, dried beans, and condiments have also been reduced.

However, removal from this catalog does not mean that these products are outside China's regulatory requirements. The categories removed from the official-recommendation catalogue may still be subject to applicable overseas enterprise registration and declaration requirements under GACC Announcement No. 219 of 2025, where they fall within the scope of imported primary edible agricultural products.

Businesses should therefore reassess their product classification and applicable registration or declaration pathway.

Some Products Are Excluded from Automatic Renewal

The revised GACC registration requirements for food manufacturers provides for automatic renewal of registration for enterprises that meet the applicable requirements.

However, this does not apply to every food category.

Currently, the following categories are listed as not eligible for automatic registration renewal:

GACC has stated that this list will be updated dynamically based on risk assessment.

For businesses operating in these categories, registration renewal therefore requires particular attention.

Certain Cold Storage Facilities Must Register

The revised requirements also clarify registration obligations for storage enterprises.

Cold storage facilities storing:

• Terrestrial animal-derived food
• Aquatic products

are required to register under the clarified requirements.

The requirement is linked to risks associated with low-temperature transportation and is aligned with international practice and current domestic standards.

Accordingly, the registration framework extends beyond overseas food production and processing enterprises to specified overseas food storage enterprises, specifically cold stores used to store terrestrial animal-derived food and aquatic products.

Import Declaration Requirements Have Been Clarified

The announcement also clarifies requirements related to registration information and import declarations.

These requirements apply to food entering China as:

Cargo for human consumption OR Raw materials for food processing

The announcement also addresses food originating from enterprises whose registration status is:

• Suspended
• Deregistered
• Revoked
• Otherwise, abnormal, including transitional treatment for products shipped before such status changes.

For overseas businesses, maintaining an appropriate registration status is therefore an important consideration when supplying food to China. Import declarations must include the applicable GACC registration number of the overseas production enterprise.

Registration Activities Are Managed Through a Single Registration Platform

The China Import Food Enterprises Registration (CIFER) system for food manufacturers is the designated platform for registration-related activities.

Businesses can use the system for:

GACC also confirms that no registration fees are charged.

Requirements for GACC Registration for Overseas Food Manufacturers

The revised framework makes it important for businesses to review their existing registration position.

Business checklist

• Review product classification
  Check whether your products fall within the updated catalog requiring official recommendation.
• Check renewal requirements
  Determine whether your products are eligible for automatic renewal.
• Review storage arrangements
  Assess whether relevant cold storage facilities are subject to registration.
• Verify registration status
  Ensure that the registration status of relevant enterprises remains appropriate for imports.
• Review declaration requirements
  Check the applicable registration and import declaration requirements for your products.
• Monitor regulatory updates
  The list of food categories not eligible for automatic renewal may be updated dynamically.

What This Means for Businesses

The changes do not represent a single change to the GACC registration requirements for food manufacturers. Instead, they clarify different parts of the framework, from which products require official recommendation to how registration renewal, storage facilities, and import declarations are handled.

For overseas food manufacturers, the immediate priority should be to determine whether the updated requirements affect their product category, registration status, renewal process, or supply chain.

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Conclusión

China's updated registration framework brings greater clarity to the administration of overseas food manufacturers and related enterprises.

Los cambios clave incluyen:

• 17 food categories requiring official recommendation
• 2 categories currently excluded from automatic renewal
• Certain cold storage facilities now subject to registration
• One central platform for registration activities

Businesses exporting food to China should review their current registration position against these changes and continue monitoring updates from GACC.