Critical Information – Change is Coming
The Chinese Government holds a National Congress soon after the Chinese New Year period, where several announcements are made concerning the structure and focus for the Government for the coming year. At the 2018 Congress, it was announced that a new agency, the State Administration for Market Regulation (SAMR) would be formed. This will essentially be a merging of three existing agencies, CFDA, AQSIQ and the State Administration for Industry and Commerce. With the announcement of the SAMR formation, the CIQ function will shift from its alignment with the AQSIQ and will form part of the portfolio managed by the General Administration of Customs People’s Republic of China (GACC).
The new Agency was ratified on April 10, 2018 but the timing for the transition of the operational functions of the individual agencies being merged has not yet been made public. Therefore, until further notice, the existing processes should still be followed. It is expected that approval times for many functions will be slower than usual during this period of transition.
What can go wrong?
For several years, Chinese consumers have become increasingly keen to get access to Australian dairy products. With a population of more than 1.4 billion people, and an ever-increasing percentage of these joining the middle and upper level socio economic sectors, the demand for high quality dairy products continues along a very healthy trend.
In 2017, China imported 2.7 million tonnes of dairy products with a value of US$8.3 billion. Of this, Australian exports accounted for 185,000 tonnes and US$625 million.
There are many challenges in exporting to China, and although the rewards can be great, the risks must be carefully assessed.
The Australian Dairy Industry is keen to ensure people are well-informed about what they’re taking on and would like people to understand that by becoming an exporter of dairy to anywhere creates risk for them as individuals; but also poses a broader reputational risk to the Australian dairy industry if something goes wrong.
According to Administrative Provisions on Filing of Importers and Exporters of Foods (AQSIQ), food exporters and importers of the listed food categories should complete registration with AQSIQ through an online filing management system prior to initial export to China. This simple and free procedure requires inputting basic company information and takes around three working days for approval
Administrative Provisions on Filing of Importers and Exporters of Imported Foods (AQSIQ Order No.55-2012)
All dairy products exported to China, via this distribution model, are governed by the requirements of the Food Safety Law. Dairy products must all meet the requirements of the relevant GB standards.
What are GB standards?
GB standards are China’s national standards, also known as ‘Guo Biao Standards’. China’s GB Standards are classified in two stages by their prefix code: GB are Mandatory standards; GB/T are Recommended standards (Quasi-Mandatory standards).
Mandatory standards have the force of law as do other technical regulations in China. They are enforced by laws and administrative regulations and concern the protection of human health, personal property and safety.
In addition to the General Standards which may apply (listed below), there are specific GB Product Standards for each product category which must be complied with. Relevant GB Product Standards are found in the specific product sections of this site.
Standard-classified by content
GB7718 General Standards about labelling of pre-packaged food
GB13432 General Standards about labelling of pre-packaged food for special use
GB28050 General Standards about nutrition labelling of pre-packaged food
GB2760 Usage standards of food additives
GB14880 Usage standards of food nutrition fortifier
GB2761 Maximum limits of mycotoxins in foods
GB2762 Maximum levels of contaminants in food
GB2763 Maximum residue limits for pesticides in food
GB29921 Maximum levels of pathogenic bacteria in foods
GB Manufacturing Standards
GB 14881-2013 General Hygiene Practice for Food Production
GB 31621-2014 Hygiene Practices for Food Operation Processes
GB.T 27342-2009 HACCP System-Requirements for Dairy Processing Plant
GB 5749-2006 Standards for Drinking Water Quality
GB 12693-2010 Good Manufacturing Practice for Milk Products
GB Test Method Standards
GB 4789.10-2016 Safety Standard Food Microbiological Examination Staphylococcus Aureus
GB 4789.26-2013 Safety Standard Microbiological Examination-Commercial Sterillization Examination
GB 5009.5-2016 Determination of Protein in Foods
GB 5009.6-2016 Determination of fat in foods
GB 5009.24- 2016 Determination of M-Group Aflatoxins in Foods
GB 5009.90-2016 Determination of Iron in Foods
GB 5009.239-2016 Determination of acidity in foods
GB 5413.30-2016 Determination of Impurities in Milk and Milk Products
GB 4789.1-2016 Safety Standard Food Microbiological Examination-General Rules
GB 4789.2-2016 Safety Standard Food Microbiological Examination Aerobic Plate Count
GB 4789.3-2016 Safety Standard Food Microbiological Examination Enumeration of Coliforms
GB 4789.4-2016 Safety Standard Food Microbiological Examination Salmonella