FOOD EXPORT TO CHINA

China issued the draft Administrative Measures on General Certification of Imported Food for the so-called “Harmonized certificate” in order to allow export of food products from other countries to China. Now, the „Harmonized certificate“ introduction has been postponed for 2 years.

As it was expected before, China applied for a 2-year transitional period for the so-called Harmonized Certificate. This basically means that only from October 1, 2019 importation of food products shall be subject to such Harmonized Certificates.

The Regulation requires that a new certificate shall be issued by the competent authorities of exporting countries to certify that the batch of food products being exported to China has been produced, processed, stored, transported and exported under effective supervision from the authority, and is suitable for human consumption. Import will be prohibited for products without such certificate.

Authorities of Countries exporting food to China now shall start to work on preparing drafts of such new certificates – which shall also be in Chinese language (!) – and submit them in due time to AQSIQ (General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China). As food products are usually under the jurisdiction of different authorities even within the same Country, coordination and consistency shall be one of the main difficulties for both exporting Countries’ authorities, and AQSIQ (which very likely will be flooded by drafts and documents…). It will be anyway a real challenge, if one considers the big number of certificates that have to be set up and send in for approval. Different food businesses need different licenses. Food production concerns food factories, and refers to 32 sub-categories, each one regulated by specific regulations and standards.

It should be mentioned, that the regulation also leaves many open questions.

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