Major Update | Interpretation of GACC Decree No. 280: Key Updates on the Registration of Overseas Food Manufacturers Exporting to China
On 14 October 2025, the General Administration of Customs of China (GACC) officially released Decree No. 280 — Provisions on the Registration of Overseas Manufacturers of Imported Food.
The new regulation will take effect on 1 June 2026, upon which GACC Decree No. 248 (2021 version) will be repealed.
This report summarizes the major changes introduced by Decree 280 and compares them with the previous rules under Decree 248. It aims to provide guidance for food importers, overseas manufacturers, foreign competent authorities, and industry organizations.
Key Updates and System Framework Under Decree 280
1. Clearer Definition of Scope and Regulatory Targets
Decree 280 applies to all overseas enterprises engaged in the production, processing, or storage of food intended for export to China.
It explicitly excludes manufacturers of food additives and food-related products, making regulatory boundaries more precise.
2. Introduction of “Catalog Foods” for Classified Supervision
The new regulation adopts a two-tier structure:
Catalog Foods (high-risk categories) → Must be registered through recommendation by foreign competent authorities
Non-Catalog Foods (low–medium risk) → Registration may be applied for directly by enterprises
Compared with the fixed list of 18 categories requiring recommendation under Decree 248, Decree 280 introduces a dynamic catalog system, enabling more flexible and science-based risk management.
3. Removal of the “Equivalence Assessment” Requirement
Under Decree 248, some registrations required China to perform an “equivalence assessment” of a foreign country’s food safety system—a major procedural bottleneck.
Decree 280 eliminates this requirement, replacing it with:
The enterprise must be under the legal supervision of the foreign competent authority；
The enterprise must comply with inspection and quarantine requirements mutually agreed between China and the exporting country；
The enterprise must maintain an effective food safety and protection system.
This change significantly reduces pre-registration administrative burdens and improves efficiency.
4. More Flexible Registration Methods: Introduction of “List-Based Registration”
In addition to individual enterprise applications, the new rules introduce: List-Based Registration, which means a foreign competent authority reviews and submits a list of enterprises proposed for registration. GACC then conducts a centralized assessment and unified approval.
This provides a more efficient option for countries with many exporters.
5. Registration Validity and the New “Automatic Renewal Mechanism”
The registration validity remains five years, but Decree 280 adds a major improvement. Most registrations will automatically renew for another five years. Only the following conditions require active renewal:
- Product falls under the “non-automatic renewal list”;
- Enterprise is under corrective action;
- Food exports from the country are suspended or restricted
additional requirements imposed by GACC.
Compared with the old rule that required mandatory renewal applications every five years, Decree 280 greatly reduces compliance workload for enterprises.
6. Clear Provisions for Special Business Models
The new regulation includes explicit clauses stating that GACC will separately formulate rules for: Registration of overseas storage facilities; Registration of overseas producers of primary edible agricultural products; Registration requirements for overseas manufacturers involved in cross-border e-commerce (CBEC) retail imported food.
This establishes the legal foundation for expanding regulatory coverage in the future.
For the first time, Decree 280 formally states that separate regulatory rules will be developed for overseas manufacturers supplying food through CBEC retail channels. Although the provision is general in nature, its inclusion is highly significant:
✔CBEC retail imported food will formally enter China’s overseas manufacturer registration framework
✔ A dedicated, independent regulatory mechanism will be created
✔ Requirements will differ from general trade
Given that CBEC retail food imports continue to grow rapidly—covering infant formula, snacks, health supplements, beverages, wine, coffee, etc.—associated food safety risks have increased. Potential future regulatory models may include:
- Record-filing system: Overseas enterprises upload compliance documents for filing before entering CBEC platforms
- Simplified registration: Fewer requirements than catalog foods, closer to non-catalog food registration
- Enhanced platform responsibility: Platforms must verify supplier legitimacy and compliance
By including an explicit “rules to be developed separately” clause, Decree 280 confirms that CBEC retail food will become a formal part of China’s overseas manufacturer registration regime.
The release of GACC Decree No. 280 marks a major step toward a more mature and modern regulatory system for overseas food manufacturer registration.
Overseas producers, importers, exporters, and foreign competent authorities are advised to study the new regulation in detail, understand changes affecting catalog categories, application pathways, and renewal procedures, prepare for transition before 1 June 2026. Doing so will help ensure compliance, minimize business disruption, and maintain stable supply chains for the China market.