Exporting Food to China: GACC Registration Under Decree 248 and Its Replacement, Decree 280

Before a single carton of food can clear Chinese customs, the overseas plant that made it must be registered with the General Administration of Customs of China (GACC) and the importer must quote that plant's China registration number on the customs declaration. From 1 January 2022 the rule was GACC Decree No. 248. As of 1 June 2026, Decree 248 is repealed and replaced by GACC Decree No. 280, the revised Administrative Provisions on Registration of Overseas Manufacturers of Imported Food. The structure is familiar (higher-risk foods registered on the recommendation of the exporting country's authority, everything else self-registered online through the CIFER system), but the category list, renewal rules and scope changed. Existing registrations carried over. This guide explains the system as it stands in October 2026, and what a shipment without a valid number runs into at the border.

What GACC registration is, and what it is not

GACC registration is a facility registration. It attaches to the overseas production, processing or storage site, not to a product, a brand or a trading company. Article 2 of Decree 280 applies it to overseas enterprises that produce, process or store food exported to China. A trader or exporter who does not own the factory cannot register on its behalf as if it were the manufacturer; the trader has its own, separate filing obligation (covered below).

It is also distinct from three things exporters often confuse it with:

• Market access. For many animal and plant products, China only accepts a given product from a given country once the two governments have agreed a protocol and GACC lists that country and product as eligible. Registration does not open a market that is closed.
• Health, veterinary and plant health certificates. Shipment-level certificates issued by the exporting country's authority still travel with the goods where a protocol requires them. Our guide to phytosanitary certificates and plant import permits covers how those certificates work in general.
• CCC certification. The China Compulsory Certification mark applies to listed manufactured goods such as electrical appliances. It is not a food requirement, and it only matters to a food shipper who is also shipping equipment.

Decree 280 also states what it does not cover: manufacturers of food additives and food-related products (packaging and other food-contact materials) are excluded and fall under separate rules.

Decree 248 vs Decree 280: what changed on 1 June 2026

GACC published Decree 280 on 14 October 2025 and issued its implementing notice, GACC Announcement No. 27 of 2026, on 18 March 2026. Article 33 of Decree 280 sets the effective date of 1 June 2026 and repeals Decree 248 from the same day. The main differences:

GACC said at the time of the announcement that about 96,000 overseas food enterprises were registered and that about 95% of them would qualify for automatic renewal. The Singapore Food Agency's trade circular of 28 July 2026 also notes that the grounds for revoking a registration grew from seven to nine, adding a major food safety incident caused by the manufacturer and serious food safety problems found at border inspection.

The 17 categories that need the exporting country's recommendation

For higher-risk foods, the overseas manufacturer must first be audited by the competent authority of its own country (a ministry of agriculture, a veterinary service or a food safety agency, depending on the country). The authority issues an inspection report and a recommendation letter, and the application then goes to GACC. Under Decree 280 the manufacturer can lodge that application itself or through an authorised agent, with the recommendation documents attached; under Decree 248 the authority submitted it. Annex 1 to Announcement No. 27 of 2026 lists the 17 categories:

1. Meat and meat products
2. Casings
3. Bird's nest and bird's nest products
4. Bee products
5. Eggs and egg products
6. Edible oils and fats
7. Stuffed wheaten products (filled pasta and dumplings)
8. Edible grains
9. Milled grain products and malt
10. Dehydrated vegetables
11. Seasoning powders
12. Nuts and seeds
13. Dried fruits
14. Foods for special dietary purposes
15. Health foods
16. Dairy products
17. Aquatic products

Two practical notes. First, the recommendation step means the exporter's timetable depends on its own government's audit capacity, which varies a lot between countries; start with the competent authority, not with GACC. Second, products that dropped off this list did not necessarily become unregulated. Separately from Decree 280, GACC Announcement No. 219 of 2025 (in force since 15 December 2025) set up a quarantine-side registration for a catalogue of primary agricultural products, declared under licence code 302 rather than 519. Check whether your product sits in that catalogue before assuming the lighter route applies.

Self-registration through CIFER for everything else

Food outside the 17 categories (confectionery, biscuits, beverages, wine and spirits, canned food, most ready meals and many other processed foods) goes through self-application. Under Article 9 the manufacturer, or an agent it appoints, submits the application directly to GACC online.

Every registration matter, for both routes, runs through the CIFER system (China Import Food Enterprise Registration) on China's Single Window, at cifer.singlewindow.cn. That covers new applications, changes, renewals, suspensions and reinstatements. GACC charges no fee for registration. Paid "registration services" exist, some legitimate agents and some imitation sites, so make sure anything you pay for is an agent you appointed and that the application actually lands in CIFER.

A typical self-application includes:

• the enterprise's legal details and the registration or licence issued by its home authority;
• the site address, the production, processing or storage activities, and the food categories and HS codes to be exported;
• a description of the food safety and hygiene management system (HACCP or equivalent);
• a declaration that the plant complies with Chinese law and Chinese national food safety standards.

Getting the product classification right matters, because the category registered is checked against what is declared at the border. Our guide to finding the right HS code is a useful starting point. Registered enterprises, with their numbers and validity dates, are listed on the GACC website, so an importer can check a supplier before it ships.

The registration number on the packaging

Article 14 of Decree 280 requires a registered enterprise exporting to China to mark its China registration number, or the registration number approved by its own country's competent authority, on the food packaging. Decree 248 spelled out "inner and outer packaging"; the new text says packaging without that distinction. Until GACC guidance says otherwise, the safe practice is unchanged: put the number on the retail pack and on the shipping carton, so it can be read wherever an inspector opens the load.

Some product groups carry more detailed rules in GACC Decree No. 249 (the Administrative Measures on Import and Export Food Safety, in force since 1 January 2022, and not replaced by Decree 280). Article 30 of Decree 249 requires:

• Chilled and frozen meat: inner and outer packaging marked in Chinese, or Chinese plus a foreign language, with the country of origin, product name, establishment registration number and batch number; the outer packaging must also show specification, origin down to state or province, production date, shelf life and storage temperature, with China marked as the destination and the exporting country's official inspection mark affixed.
• Aquatic products: product name and scientific name, specification, production date, batch, shelf life, storage conditions, production method (sea catch, freshwater catch or farmed), area of catch or production, and every processing and storage enterprise with its registration number and address.
• Health foods and special dietary foods: the Chinese label must be printed on the smallest sales package. A stuck-on label is not accepted for these two groups.

Shipping marks on the outside of the case are a separate job; see cargo marking and labelling for what typically goes on a carton.

Chinese labels: the importer's responsibility, with a new standard coming

All imported prepackaged food must carry a Chinese label that meets Chinese law and the national food safety standards. Outside health foods and special dietary foods, a compliant Chinese sticker label is generally accepted, and customs checks labels as part of its conformity assessment and on-site inspection. Decree 249 makes the importer answerable for a missing or non-compliant Chinese label (Article 70 allows a warning or a fine of up to 10,000 yuan where an importer refuses to correct, return or destroy such goods).

The general labelling standard is changing. GB 7718-2025 (prepackaged food labelling) and GB 28050-2025 (nutrition labelling) were published on 27 March 2025 and take effect on 16 March 2027, replacing the 2011 versions. Packaging printed in late 2026 for a long shelf life should be checked against the new standards, not only the old ones.

What the importer files, in brief

Registration of the factory is only one leg. Under Article 19 of Decree 249:

• the overseas exporter or its agent must file a record with GACC, and update it within 60 days of any change;
• the Chinese importer (consignee) must file a record with the customs office where it is domiciled, keep import and sales records, and audit its overseas suppliers.

Since 1 June 2026, Announcement No. 27 also fixes how the registration number is declared. For food imported as cargo, for human consumption or as a food processing ingredient, the declarant enters the overseas manufacturer's China registration number under "Product qualifications", in the overseas manufacturer registration field (licence category code 519), and enters "edible" (食用) as the purpose. The number must match the declared country of origin. This is a separate data field from the label; a correct label does not fix a blank field. Cross-border e-commerce retail imports for personal use were reported by regulatory advisers in 2026 to be exempt from the registration requirement; if that is your channel, confirm the current position with your platform or a Chinese customs broker.

The importer also needs the usual commercial set, which our import documentation checklist lists in general terms: commercial invoice, packing list, bill of lading or air waybill, certificate of origin where a preference is claimed, and any health or veterinary certificate the protocol requires.

What happens at the border if the number is missing or wrong

Announcement No. 27 is blunt: imported food without a valid overseas manufacturer registration number is not permitted to be imported, and where the number is not declared as required, customs does not accept the declaration. In practice that means the container sits at the port accruing storage, and for a reefer, plug-in charges, while the importer tries to correct the entry. If the manufacturer was never registered, there is nothing to correct.

Where goods are inspected and found non-compliant on safety, hygiene or environmental grounds, Article 33 of Decree 249 has customs order them returned or destroyed. Other defects (a label problem, for example) may be put right by "technical treatment" under customs supervision, if it can be done in time; otherwise the goods are again returned or destroyed. For perishable cargo, "returned" usually means a second ocean leg on a product that was already part-way through its shelf life. Preparing the reefer properly matters on both legs: see reefer PTI and cold chain monitoring.

Announcement No. 27 also sets transitional rules that help in some cases. Food made while a registration was valid, and still within shelf life, can be declared after the registration lapses where it was a recommended-category product; reports differ on whether the same applies to self-registered categories, so check the registration is live on the declaration date. And where GACC suspends, cancels or revokes a registration, food that left the origin before that date can still be declared.

Common misconceptions

• "Our importer is registered, so we are covered." The importer files a record; the overseas manufacturer registers. Both are needed.
• "Decree 248 registrations had to be redone." They did not. Valid registrations carried over on 1 June 2026, and most now extend automatically.
• "Auto-renewal means nothing to watch." Meat and bird's nest makers still apply, 3 to 12 months before expiry. Auto-renewal also stops if the plant is under rectification or GACC has suspended imports of that category from its country.
• "Coffee beans no longer need anything." They left the Decree 280 recommendation list, but primary agricultural products may fall under the separate Announcement 219 catalogue. Check it.

What to do next

1. Confirm that China accepts your product from your country (market access), then confirm whether it is in the 17 recommended categories or the Announcement 219 catalogue.
2. Check the manufacturer's status and expiry date in the GACC registered-enterprise list, or register through CIFER (directly for self-application, via your competent authority's audit for the 17 categories). If you rely on a third-party cold store for meat or seafood, confirm it is registered too.
3. Put the registration number on the packaging, check the Chinese label against GB 7718 (and the 2025 version from 16 March 2027), and give the importer the number in writing for the code 519 field.
4. Agree with the importer or its broker who checks the declaration before the ship sails, not after it arrives. If you are unsure who should file what, our guide on whether you need a customs broker sets out the roles.

China's rules sit beside, not instead of, those of other markets: if you also ship food to the United States, our guide to FDA Prior Notice and FSVP covers the equivalent filings there. To find a forwarder or customs broker with China food experience, more than 29,300 logistics companies are searchable by country and service in the CargoLinked directory, and the public requests board lists freight that shippers have posted for forwarders to quote on directly.

This article is general information about Chinese import food rules as of October 2026, not legal, customs or regulatory advice. GACC updates its catalogues and lists dynamically, and translations of Chinese regulations are unofficial. Confirm current requirements with GACC, your country's competent authority or a licensed customs professional before shipping.