A New Rulebook for Food Imports
China's General Administration of Customs replaced Decree 248 with Decree No. 280 on June 1, 2026. It is the new legal basis for registering overseas food manufacturers that want to sell into China. If you already export food to China, your registration number remains valid, but the rules around it have changed. If you are preparing your first shipment, many of the older guides you will find online are now out of date.
Three changes matter most to exporters. First, the list of products that must be recommended by a national authority has been reorganized into 17 categories. Second, products outside that list follow a self-application path that does not require government recommendation. Third, several raw agricultural products have moved out of the food registration system entirely and now fall under a separate agricultural product framework.
Who Must Register
Registration applies to overseas manufacturing, processing, and storage facilities that handle food destined for China. That sounds straightforward, but the details trip up many companies:
- Manufacturers. Any facility that produces food for export to China must hold a valid registration.
- Processors. Facilities that turn raw materials into finished food products are covered the same way.
- Storage facilities. Only cold storage for terrestrial animal-derived food and aquatic products counts as a registrable storage facility. A general warehouse does not qualify.
- Trading companies. A pure trading company without production or processing facilities cannot register in its own name. Registration belongs to the facility that actually makes or handles the food.
This last point causes more confusion than any other. We regularly meet exporters who are told by intermediaries that their trading company can simply register itself. Under Decree 280, that path does not exist. The registered entity has to be the plant, the processing line, or the qualifying cold store.
How Products Are Classified
The 17 Recommended Categories
Products in these 17 categories must be registered through the competent authority in the exporting country, which then recommends the facility to GACC:
| Category | Category |
|---|---|
| Meat and meat products | Dried vegetables |
| Casings | Seasoning powders |
| Bird's nest and bird's nest products | Nuts and seeds |
| Bee products | Dried fruits |
| Eggs and egg products | Foods for special dietary purposes |
| Edible oils and fats | Health foods |
| Stuffed pastry | Dairy products |
| Edible grains | Aquatic products |
| Grain milling products and malt |
Two of these categories, meat and meat products and bird's nest products, do not automatically renew. Their registrations must be actively extended before expiry.
Self-Application for Everything Else
Food products outside the 17 recommended categories follow a self-application path through the CIFER system, operated by GACC at cifer.singlewindow.cn. No recommendation letter from the exporting country's authority is required. This covers a wide range of everyday foods such as roasted coffee, tea, sugar, confectionery, snacks, and beverages.
What Moved Out
Six raw agricultural products were removed from the food registration system altogether: oilseeds, miscellaneous grains, fresh vegetables, dried beans, seasonings, and unroasted coffee and cocoa beans. These now fall under GACC Announcement No. 219 of 2025, which manages overseas enterprise registration for agricultural products. The distinction matters because the two systems use different registration channels and different declaration codes.
Case Study: An Indonesian Roaster's Path to Registration
An Indonesian coffee company approached us with a specific problem. Their buyer in China had written GACC registration into the contract as a condition of the deal, and the roaster had no idea where to start. They had a real production facility with a roasting line and a packing line, so they were a legitimate candidate. What they lacked was clarity.
Step 1: Product Classification
The first question was which system applied to them. The answer hinged on a distinction that confuses many exporters: unroasted coffee beans are an agricultural product under Announcement 219, while roasted coffee beans and ground coffee are food products under Decree 280. Because the company roasted and packed coffee, their products fell in the food category, outside the 17 recommended categories, which meant they could use the self-application path without a recommendation letter from an Indonesian authority.
Step 2: Verifying the Registration Entity
We then confirmed the registration had to be filed in the name of the roasting facility itself, not the trading arm of the group. The facility's operating license, address, and production capability all had to line up with what we submitted to the system.
Step 3: Preparing the Dossier
The core submission needs three things under Decree 280: the enterprise registration application information, proof of identity such as the local business license, and a declaration that the facility meets the registration conditions. Our team gathered the Indonesian documents, prepared the application details in the format the CIFER system expects, and arranged English translations for everything that needed them.
Step 4: Submission and Follow-Up
We registered the account, filed the application through CIFER, and tracked it through the review process. The application was approved in about 20 working days, and the company received a registration number beginning with C, which is the format GACC uses for registered overseas food facilities.
Step 5: The Parts That Come After
Registration was the gate, not the finish line. We walked the company through the overseas exporter filing, showed them how the registration number is declared on customs documents, and flagged the Chinese label requirements for their retail packs. When their first container shipped, every compliance piece was in place before the goods left the port.
The company's takeaway was simple: the hard part was never the application form. It was knowing which system applied, whose name had to be on the registration, and what to prepare before touching the system at all.
Common Mistakes We See
- Registering the wrong entity. A trading company filing in its own name gets rejected, and in some cases a registration obtained with inaccurate information can be withdrawn later.
- Misclassifying the product. Coffee is the classic example. Unroasted beans and roasted coffee sit in different regulatory systems, and mixing them up stalls the application.
- Submitting without translation. Documents in the local language need English translations. Missing or sloppy translations are a common reason applications bounce back for correction.
- Treating registration as the only step. Customs declaration codes, exporter filing, and label compliance are separate requirements. Registration alone does not clear a shipment.
How We Can Help
We handle GACC registration for food and beverage exporters end to end. We assess which registration path your product falls into, verify the correct entity to register, prepare the dossier with translations, submit through CIFER, and follow up until the registration number is issued. We also cover the downstream pieces: exporter filing, customs declaration support, and label compliance.
Contact us for a free compliance assessment of your GACC registration needs.
