Jurisdiction - China
Reports and Analysis
China – Provisions Governing Overseas Manufacturers of Imported Food.

29 April, 2012


Legal News & Analysis – Asia Pacific – China – International Trade


On March 22, 2012, the State Administration of Quality Supervision, Inspection and Quarantine issued the Provisions for the Administration of the Registration of Overseas Manufacturers of Imported Food, which will take effect on May 1, 2012 and supersede the Provisions for the Administration of the Registration of Foreign Manufacturers of Imported Food, issued in 2002. The new provisions continue to require overseas food manufacturing, processing and storage enterprises to complete a registration procedure with the Certification and Accreditation Administration of China before their related food products may be imported to China. The registration number is valid for four years and the registration may be renewed during the year before the registration number expires. The registration number will be cancelled if an overseas food manufacturer (1) fails to file the renewal application within the prescribed time period, (2) causes a major food safety incident, (3) exports unqualified food to China, or (4) leases, lends, transfers, sells or alters its registration number.  Penalties may be imposed on the importer of the food products of an overseas food manufacturer that fails to complete the registration procedure. 

The full Chinese text of the provisions is available here.
For further information, please contact:


Elizabeth Cole, Partner, Orrick

Thomas Man, Partner, Orrick
Brad Herrold, Orrick
Veronica Lockyer, Orrick
Yan Zeng, Orrick



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