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The Exporter Regulatory Advice Service (ERAS) supports New Zealand exporters by making it easier to understand the Ministry for Primary Industry's (MPI) exporting requirements.

Recordings of past webinars, presentation slides, and resources are available to view below.

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China Registration of Food Manufacturing Establishments (Decree 248)

26 February 2024

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Topics covered

Who does Decree 248 apply to
Introduction to Decree 248
The 2 different methods of China manufacturer registration

This webinar is for manufacturers and exporters of food to China who want a better understanding of China’s Decree 248 requirements and how to register. The presentation covers registration requirements in Decree 248 only – other requirements to export to China still apply.

Note: Information in the slides was current as of 18 January 2024 but may be subject to change without notice.

Video: China Registration of Food Manufacturing Establishments (Decree 248) (34.34)

Transcript

Webinar – China Registration of Food (Manufacturing) Establishments (Decree 248)

Slide 1 – Title: China Registration of Food (Manufacturing) Establishments (Decree 248)

[Grace] Kia ora koutou and thank you for joining us today; welcome to our webinar on the China Registration of Food Manufacturing Establishments for Decree 248.

My name is Grace Powell and I work in MPI’s exporter regulatory advice service team, also known as exporter help for short and I’m joined today by my colleague Samantha Tiller from our China Market Access team.

Please note the information we will be presenting today is up to date as of 19 January 2024 but could be subject to change. We recommend ensuring you subscribe to MPI OMAR and FYI updates, and to keep in touch with your Chinese importers on a regular basis as things can change.

And just to clarify, today we’ll only be talking about registration requirements per Decree 248 – there may be other registration requirements that apply to you for the export of food to China, depending on your business.

Slide 2 – Title: What we’ll cover today

[Grace] Right, so what we will cover today: first, do you need to register, and should you keep watching? Then an introduction to Decree 248, followed by information about the different registration methods. We’ll also take a closer look at self-registration, then wrap up the presentation.

Slide 3 – Title: Who needs to register under Decree 248

[Grace] So, who needs to register?

Manufacturers of most foods and beverages for human consumption need to register with China Customs under Decree 248.
There are also a few instances where stand-alone cold storage establishments, currently for meat and aquatic products, need to register.

Who doesn’t need to register under Decree 248?

You don’t need to register under Decree 248 if you are making food additives or food-related products like packaging.
You don’t need to register if you are an ambient store that doesn’t process or repack food.
And if you’re an Exporter not involved in manufacturing or storing the product, you also won’t need to register, but you’ll still want to learn about the Decree 248 requirements to make sure your manufacturers have met these to help ensure a smooth export for you.

Do note though that Exporters need to be aware of China’s Decree 249, which requires food exporters to file with China Customs. MPI isn’t involved in this process, so if you need further information about exporter filing with China Customs, have a talk to your importer, or NZTE also have some helpful information about exporter filing on their website.

You also don’t need to register if you are making product categories that are not in scope of Decree 248. A lot of the time this is because they are managed by another part of GACC (China Customs) – the animal and plant quarantine side – and their registration methods are different. So, if you’re not in scope of Decree 248, you should still have a think about whether a different China registration might still be required. Some examples include live seafood, fresh fruit, products not for human consumption like fishmeal, pet food, hides and skins. For their registration methods, your first port of call is usually the China OMAR, we won’t be covering those types of registrations here today.

So, if it sounds like you might need to register with China Customs under Decree 248 because you make food or beverage for export to China, or if you’re just interested in learning more, keep listening and we’ll introduce you to some more information on this.

I’ll now pass over to Sam who will take us through a brief introduction.

Slide 4 – Title: Introduction

Slide 5 – Title: Key Definitions

[Sam] Kia ora, I'm Samantha Tiller from MPI Market Access and I’m now going to take you through a basic introduction about what Decree 248 means for New Zealand operators.

Firstly, I’ll go through some definitions of terms that we’ll be using today.

Firstly, G- A – C – C – also known as GACC – this stands for the General Administration of China Customs. This is the Chinese government agency that is responsible for Decree 248.

The second one is CIFER – this stands for China Imported Food Enterprise Registration and is China’s online registration platform that you do your registration on and that MPI also uses.

And thirdly, MPI Registration Number – this is the ID for your risk-based measure that MPI has approved. Examples are RMP (for most animal products), RCS (registered control scheme such as for fishing vessels), ULI (for dairy), WSMP (for wine), Food Control Plan (under the Food Act) or National Programme (under the Food Act)

Slide 6 – Title: Decree 248

[Sam] I’ll start with what Decree 248 means. It means that most New Zealand establishments that manufacture food products for export to China need to register with China Customs (or GACC). Note that some stand-alone cold stores also will have to register, specifically for meat and seafood only.

This requirement came into effect on the 1st of January 2022.

There are two different methods to apply for registration with GACC, and the one you have to use depends on the product that you’re making for China at the site you are registering. This introduction section is relevant to both methods, and we’ll go into more detail of each method later on.

In addition to the registration requirement, there is also a labelling requirement. We will talk about this in a little more detail later as well, but in short, all products manufactured after the 1st of January 2022 that are to be exported to China must be labelled with either the China Registration Number for that establishment (this is a number assigned by GACC once the establishment is registered), or with your MPI registration number (so that’s your RMP, ULI, Food Act Registration Number or WSMP)

Slide 7 – Title: China Import Food Enterprises Registration (CIFER)

[Sam] China has set up this website China Import Food Enterprises Registration (or CIFER) website for you to use to apply for registration or to apply to change your registration information.

It’s also the platform where all your establishment’s registration information is kept.

You have to have an account login to access it. There are several ways to set up a CIFER account login and each login is directly linked to your MPI registration number (remember that this is your risk-based measure that MPI has approved, such as RMP, RCS, ULI, WSMP or Food Act Registration number).

If you are unsure how to set up a CIFER account, please contact MPI and we can help you to set it up correctly.

Slide 8 – Title: China Establishment Registration

[Sam] So regarding China establishment registration, you need to register your establishment, but what for what exactly?

Well, you’ll need a CIFER user account for each manufacturing site you manage that makes product for export to China and also for each or standalone cold store if its storing meat or aquatic products for export to China.

From that user account (ie for each manufacturing site or standalone cold store that you manage), you’ll need a China Registration for each product category that is made at that site for export to China. This means one site may have more than one China Registration (i.e., for different product categories).

Each registration gets a unique China Registration Number assigned to it as well (we’ll talk about more on that in the next slide) That means that one site may have more than one China Registration Number for different product categories.

It’s really important to make sure you are registered correctly and have a China Registration Number for all the different product categories that you make for China, as this information is used for the import declaration, and it’s checked by China for border clearance. We understand this part can be a little bit confusing, so I’ll go through an example - so say I manage two manufacturing sites and they both make the same two products for China (let’s say honey and honey lozenges). So that’s two different sites and two different product categories. I’ll need to set up a CIFER account for site A, then complete two registrations under that account – one for honey and one for honey lozenges. I’ll then need to then do the same for site B, so set up a separate account for site B in CIFER, then complete two separate registrations again - one for honey and one for honey lozenges under that login. We know this is starting to sound a bit like math’s homework, but in total, that means I’ll have four different China Registration Numbers. Site A will have one for honey and one for honey lozenges and Site B will have one for honey and one for honey lozenges.

Under each CIFER login, you can apply for new registration as well for another product category.

For each approved registration in CIFER, you can also modify that (i.e., make changes) and you can renew that registration when they’re about to expire.

Slide 9 – Title: Once an establishment is registered

[Sam] So once your registration has been approved by GACC and the establishment is registered, GACC will assign you a unique China Registration Number. This is based on the product category that the approved registration is for. This number starts with CNZL for all New Zealand manufacturers and the next four digits represent the product category for that registration e.g., 0101 is beef meat, 1702 is dairy products, 1801 is aquatic products etc.

You can see what the rest of the numbers in your China Registration Number mean on this slide.

A publicly accessible register is available through the link on the slide and that shows all establishments around the world registered with GACC and all of their China Registration Numbers (the ones starting with CNZL are for New Zealand). The website also shows (for New Zealand establishments) the MPI Registration number, site name, site address, start date of GACC registration, expiry date of GACC registration and the status of that registration. So, this site could be useful, for example, for an exporter to confirm that the manufacturers they work with are all registered with GACC.

I’m now going to pass over to Grace to finish this introduction to Decree 248.

Slide 10 – Title: Before your registration expires – apply for renewal

[Grace] Thanks Sam. Ok, so you’ve figured out your product categories, registered per site per product category and have your China Registration Number/s sorted – then what?

It’s important to know that all registrations have an expiry date. They are typically valid for five years and you can find the expiry date in that public register we just showed you, or once you log in.

To keep your registration, you’ll need to apply for renewal, or sometimes it’s called an ‘application for extension’ in CIFER, well before you reach the expiry date.

Here’s the tricky bit - you can only apply in CIFER to renew your registration during your ‘renewal window’, which opens six months before your expiry date, and closes three months before your expiry date. The button to apply for renewal disappears in the CIFER system outside of this so it’s important to mark your renewal window in your calendars. So that you can be well prepared to submit your renewal within this limited window and don’t run out of time, we recommend you start thinking about renewal at least 6 months before your expiry date.

Please also note that you can’t make changes to your information as part of a renewal, which brings us to our next slide – how to make changes to your registration.

Slide 11 – Title: For changes to your registration – apply for modification

[Grace] You can apply for modification to your registration if you need to make changes to your existing registration information in CIFER.

For example:

Adding new products within the same overall product category. So, for example, adding a Skim milk powder when I’ve already got a Whole milk powder registered within my dairy registration, or adding frozen tripe to a meat registration.
Another example is changing your company name, or
Updating any other information in your registration, including things like process information.

Slide 12 – Title

[Grace] Ok, so we just talked about how six months before your registration expires you need to apply for extension to renew your registration, so it doesn’t expire. And if you want to make changes to your registration, you apply for modification to make those changes.

However, there are some specific changes that can’t be done by applying for modification and GACC actually requires you to apply for a completely new registration.

These are:

If your manufacturing premises move (so you go to a new location), you would need to register the new location.
If your MPI registration number changes. So that’s particularly important for our Food Act people, as I understand if you don’t renew your Food Act registration on time, you’re likely to get issued a new number when you reapply, so bear that in mind.

So, if either of those circumstances apply to you, you will need to start over and apply for a new registration, you won't be able to modify your existing one.

There’s also a sometimes case here that can be quite complex, so for full details please see the FYI or OMAR relevant to you, or contact MPI if you’re still unsure. That’s if your legal representative changes. It might be ok to modify, or you might need to apply for a new registration, it depends whether the change of legal representative is because of a change of ownership. If it is, you will need to reapply for registration and you won't be able to modify your existing one.

Just a quick note that when we say legal representative, we don’t mean a company lawyer. Your legal representative is a person you specify to GACC when you’re first registering who represents your company and is responsible for the food safety of the products your site exports to China. They have to sign a lot of your declarations and documents on behalf of your company when you first register, so that’s why they’re so important.

Slide 13 – Title: Labelling requirements

[Grace] Finally, Decree 248 has labelling requirements and luckily these are quite straightforward.

All food manufactured after 1st January 2022 has to be labelled with the China Registration Number or the MPI Registration Number you used to register on the product inner (so the individual sales unit) and the outer (so the transport packaging).
Some Chinese importers or Chinese port authorities might ask you to use the China Registration.

Just a quick note that if you currently have the MPI Registration Number on the label and you want to change to the China Registration Number, don’t forget you’ll need to consider first whether it’s actually a New Zealand regulatory requirement to include your MPI Registration Number. If you want to include the China Registration Number and you fall in that category, you might need to have both and there’s nothing wrong with including both on your packaging.

Slide 14 - Title: Current MPI guidance

[Grace] To finish our introduction section, we’ll show you where to find more information from MPI on China Registration.

The China OMAR webpage is where you can find most of the useful resources, on the right side of the screen there you can see what that page looks like.

Under both animal products and processed food products, you can find a link to F36/23 – this is a detailed FYI document that contains a lot of extra information on Decree 248 including more details on things we are talking about today. No matter your product, we highly recommend you have a read of this FYI after this webinar if you haven’t already.

For those making animal products, there’s details in the Animal Products China OMAR document too, and some specific requirements.

We also have a quick CIFER guide to help you use the system, and other MPI webinars.

And again, if you haven’t already, please don’t forget to subscribe to email updates to stay up to date with any developments.

Slide 15 – Title: Registration Methods

[Sam] So I’m going to now take you through registration methods. There are a couple of methods to register a manufacturing establishment (or store) with China and I'll go through the basics of these now.

Slide 16 – Title: Two methods for registration

[Sam] The two different methods of registration are as you can see: MPI recommendation or self-registration.

Which method to use is specified by China and it depends on the product being made for China. The method is the same for a particular product category regardless of what you are doing:

a new registration (when you first apply to register)
a modification (changing some information in an existing registration you’ve already had approved), or
a renewal (when you’re already registered, and you apply to renew your registration before it expires).

The first method is MPI recommendation, and in this method the operator has to apply to MPI first. Your information gets checked by MPI, and then we recommend your application to GACC. This is all facilitated in CIFER and MPI has our own login. If you press ‘Submit’ in CIFER for an application under a product that requires MPI recommendation, that application will automatically come to MPI first for checking and then we will submit it to GACC.

The other method is self-registration. In this method, the operator applies directly to GACC in the CIFER system. MPI is not involved in self-registration. We can walk you through more details of how to do this in the coming slides.

If you get stuck on self-registration you should check the MPI guidance documents and MPI can also offer some limited advice via our Exporter Help team.

Slide 17 – Title: Method depends on product category

[Sam] So, how do you know which method to use? Well, the method depends on product category.

Products that need MPI recommendation are shown on the left-hand side of the slide. There are 18 product categories that China Customs have specified as requiring MPI recommendation.

The ones in red are those that New Zealand hasn’t yet negotiated market access into China for, so it's unlikely you will be doing a registration for them.

That leaves nine key product categories for which the registration method is via MPI recommendation.

If your product is not one of the 18 categories on the left, the method to use is self-registration.

You might remember we mentioned earlier you have to do one registration per site and per product category. So, this means that if you have a site that makes several different types of products for China you might actually have to use both methods – MPI recommendation for some products, and self-registration for some other products.

Using our previous example, if the same site makes honey and honey lozenges for China, you’ll need to register that site via MPI recommendation for the honey, because that’s defined as a bee product (number 5 on the slide on the left-hand side), and then you’ll have to self-register that site for the honey lozenges as these are defined as confectionery and come under self-registration.

Slide 18 – Title: I’m not sure if my product needs self-registration or MPI recommendation

[Sam] So, if you’re not sure what method to use for your product, between self-registration or MPI recommendation, I’m going to explain that here. So, it’s important to know this because it will affect how you go about your registration and luckily CIFER has an answer to that.

First, you’ll need to know each 13-digit HS/CIQ code for the products your site intends to make for China. These codes will go on the import declaration when your product enters China. They are made up of a 10-digit HS code and a 3-digit CIQ code. If you don’t know these HS/CIQ codes, have a talk to your Chinese importer or agent and ask them to help as they are the ones who prepare the import declaration.

Once you know the HS/CIQ codes, log into your CIFER account. You’ll see on the left-hand side a menu item called “product type query”. This is a search page where you’ll type in the 10-digit HS code and the 3-digit CIQ code and it returns some information about the product registration, including the category it comes under and the method you need to use. So, the method you need to use is seen in that far right hand column where it says “officially recommended registration”. On the slide it only says ‘officially’ dot dot dot. If the answer to that is “NO”, establishments that make that HS/CIQ code require self-registration, so you can go ahead and start completing that. If it says “YES” then that means that’s you’ll need MPI recommendation.

Slide 19 – Title: Process for MPI recommendation

[Sam] I’m now going to cover the process for MPI recommendation very briefly.

Slide 20 – Title: Process for MPI recommendation

[Sam] The process to follow for an application requiring MPI recommendation has 4 steps, starting with operator assessment. Step 2 is verification which is complete once your verifier (usually the one who verifies your MPI registration) is happy with the application. Step 3 is an email to MPI to request our recommendation and then Step 4 is the CIFER part.

The 4 steps differ slightly depending on type of application i.e., whether it’s for a new registration, whether it’s for a modification to change registration information, or whether it’s to renew a registration, and they also may differ slightly depending on the product category.

For more information about this process for applying for MPI recommendation, MPI has a separate webinar that goes into detail about this as there are quite a few more steps that you will need to know in a bit more detail and we don’t have time to cover it all here.

Slide 21 – Title: Process for MPI recommendation

[Sam] There are two published MPI processes that take you through the detail of how to apply for MPI recommendation, and which one you should refer to depends on what products are being made for China at that site.

For animal products that are within scope of the China OMAR, go to the China OMAR and look at mainly Schedule 1 of Part 1 as well as the relevant Part for that product category.

For all other products, go to the Decree 248 guidance document F36/23 and look mainly in Appendix One.

I will now hand back to Grace to talk about the process for self-registration.

Slide 22 – Title: Process for self-registration

[Grace] Ok, so we’ll now take you through a quick overview of how to apply for self-registration.

Remember, if you’re one of those MPI categories that Sam just talked about that need to go through MPI registration, now’s a good time to tune out today and go watch our other dedicated webinar on that process, as the steps are different.

Slide 23 – Title: How to self-register

[Grace] So, how to self-register. We do have some guidance linked here, please use that or follow along with this webinar if you need any help.

First, open the CIFER website. Do note that we recommend using this exact link we've put on the screen there - we have seen a few websites out there that charge money for some sort of registration, but this is the official link, and it does not cost anything. It's completely free to do your own self registration, GACC does not charge for this.

So, the image you can see on the right there is just the login page that the CIFER link takes you to. Up the top there’s two little icons, one has ‘EN’ written in a small box – if the EN is a blue box with white text, it means you’ve currently got the English version of CIFER selected.

From here, if you already have an account, login using your username and password, noting these are case sensitive.

If you don’t have an account yet and want to create one to use for self-registration, there are a few quirks to be aware of which we will talk about in a minute but first of all, definitely double check you don’t already have an account. If you’re absolutely sure you don't already have one, then click on Create an Account.

Slide 24 – Title: Create new account (only if you don’t already have one)

[Grace] This opens up another screen like you can see here. The information needed is generally quite simple, but two things to remember is that your region as an NZ based establishment should be NZL, and your registration number should be your MPI registration number. So this would be your MPI Food act registration, WSMP, ULI for dairy, or your RMP. One of the quirks is you should use the full number including anything after the forward slash for most registrations, unless you’re registering your RMP. For an RMP, in that case do not include the /01 or /02 you have.

It’s important to get this right, because once you have set up your user account you cannot edit or change the MPI registration number you’ve entered, so if you've got any doubts it's always good to check with MPI what you need to use.

Another thing to note is because China requires this to be a number related to MPI approval, you can't use your NZBN or another number that's not related to an MPI risk-based measure.

Slide 25 – Title: Main menu

[Grace] So, once you’ve logged in or created your account then logged in, this is what CIFER looks like.

The main menu is on the left there.

In the middle are announcements from GACC.

In the top right, if you click your username (which will display your chosen username for your account), you’ll go to the account management menu where you can change your login password, email address, phone number etc.

One tip is that the email address associated with the account is used for password recovery if you forget your password. So, you might want to consider how you’ll manage that if your team members change, as you don’t want to get locked out and unable to recover your password. Making sure you change the details before someone leaves or using an email a few different people have access to could be a good idea.

And finally on the top right there is an exit sign, and if you click that it will log you out of the system.

Slide 26 – Title: Main menu – useful items

[Grace] So, let’s take a closer look at the main things you’ll be using on the main menu.

The first is the ‘application for’ items.

So, 'Application for registration' is what you’d click to apply for a new registration, we’ll talk more about this more in a bit.

'Application for modification' is what you click to apply to modify or change details in your existing registration. If you click this, a table will show up of all your existing registrations, and then you just click ‘modify’ for the one you want to apply to change.

'Application for extension is what you click to apply to renew a registration'. Similarly a table will appear and you'll only be able to click extend for the ones that are within that renewal window that we talked about earlier.

Further down we have 'Integrated query', and if you click that, two more options appear.

If you click 'Application form query', this will take you to a table of all your applications in progress, where you can check their status. We’ll talk more about the different statuses and what they mean a bit later.

'Obtained registration in China' is used to show your current approved registration details.

And finally, we have 'Product type query' which we talked about earlier, and Sam showed you how to use this to check the category and registration method for your products using the HS/CIQ codes.

Slide 27 – Title: What’s needed to apply for a new registration

[Grace] So that’s our basic main menu, now let’s look at applying for a new registration.

So, from the main menu, you’d click ‘Application for registration'. You then select your product category from using the available drop downs, which takes you into a draft application form that looks like this.

An application form has a few different tabs you’ll need to fill out, and you can click each one to navigate, or at the bottom of the page there’ll be a ‘next page’ to take you to the next one.

Within the application form, some of the information requested will depend on what product you are registering, but a lot of it is kind of basic information about your site such as your address, your MPI registration number, processing capacity, that sort of thing.

If there’s an asterisk it’s compulsory information you need to enter. You’ll also need to enter the HS/CIQ codes of each product you’re registering, so it’s important to know your HS/CIQ codes ahead of time.

It’s also really important to make sure that your name and address match your MPI registered information exactly – so little things like spelling of limited versus Ltd, just double check all of those things.

You can click save as you’re filling out the form – this will save a draft for you; it doesn’t submit anything to GACC. This is handy if you need to save, exit CIFER and come back later to finish it, you can find your draft application again by clicking on 'Integrated query' in the main menu, then 'Application form query' and it will show a table of all your current applications. It will be the one that is in draft status.

When you’re filling out the application form, there are at least two documents you’ll need to upload.

The first is your ‘licensed production certificate’ which should be your MPI Registration (so an official document that shows your registration like your RMP number, ULI, WSMP, or for Food Act: Food Control Plan or National Programme).

And the second is you’ll need to upload a self-declaration which you download from the website, that’s a declaration your legal representative signs saying the information you’ve submitted is true and complete, and that you’ll be complying with all the relevant laws and regulations of both China and New Zealand.

Slide 28 – Title: What’s needed to apply for a new registration

[Grace] Once you’ve worked your way through the application form, filled in the required information and uploaded the required documents, you’ll get to the final page summarizing your attachments, like you can see on the screen. The exact attachments required will vary by product category, but from this screen, you'd click the preview button. This will show all your information as a final draft, and what you need to do is check that’s all correct, then scroll down to the bottom and you’ll see a blue submit button. Once you click the blue submit button your application will be submitted to GACC.

Slide 29 – Title: Then what?

[Grace] So, once you’ve submitted your registration to GACC, then what?

Well don’t forget you’re still not registered until GACC approves your application.

To check on the progress of your application, use that ‘Application form query’ item from the main menu.

You’ll see a table of your applications, similar to what we've got at the bottom of the screen here.

There’s a few headings to look at, and the most important is the ‘Application status’. In the example we’ve got, it shows as approved, but there are several statuses that could show here.

The main stages you are likely to see are:

Firstly, Accepted – please note this just means your application has been accepted for review by GACC, it’s a good sign your application is moving through the system but it does not mean you are approved yet.

If things have gone well, a little later you might see Approved, and that’s great, that means GACC has approved your application and you are now registered with those details.

The other two main statuses mean you’ll need to do a bit more work.

Returned – sometimes this might also be called ‘supplementation and correction’, and GACC will do this if they want you to change something and resubmit your application, so it could be for example wanting you to include some more information about something. To see GACC’s feedback, you click on 'View’ under the Customs feedback column, and you might need to google translate the pop up window. Under the ‘Actions’ column, you’ll then be able to edit what you submitted originally, fix it up and resubmit it.

Unfortunately, if your application is Refused by GACC, it means your application is deleted in the system and you’ll need to start from scratch again. You can’t get it back as a draft to fix up and resubmit, you’ll have to start a completely new application.

Slide 30 – Title: Applying for self-registration on behalf of a manufacturer

[Grace] Before we wrap up, we just wanted to give you a quick heads on using an agent or consultant for your registration.

Essentially a trusted agent is allowed to apply for self-registration on behalf of a manufacturer, this is covered in Article 9 of Decree 248. However, you should be aware that GACC published an interpretation of Article 9 that says there’s a need for an entrustment letter. So just there we’ve included a link to the FYI. There’s more details in there and a link to an unofficial English translation of the GACC interpretation, where you can find the details of those expectations for an entrustment letter.

And if you do choose to have a trusted agent outside of your business to apply on your behalf, I’d also encourage you to have a think about how you’ll manage account access after initial registration, e.g., when you need to renew your registration in 4.5 years or so, or if you wanted to modify some details.

Slide 31- Title: Thank you!

[Grace] That brings us to the end of our webinar. Thank you everyone for joining us today.

The Exporter Regulatory Advice Service (ERAS) is always here for any exporting questions you have, and we can provide some limited advice around self-registration so do feel free to get in touch using our contact details there.

And if you have any questions on MPI-recommended registration, please contact our country listings team, they will also be happy to help.

[End of transcript]

Download the China Registration of Food Manufacturing Establishments (Decree 248) presentation slides [PDF, 2.6 MB]

Process for MPI-recommended GACC Registration (under Decree 248)

March 2024

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Topics covered

Overview of the process steps and forms required for MPI-recommended GACC registration under Decree 248.
Detailed walkthrough of the registration process.
What happens next.

This webinar is for operators of establishments that process food intended for export to China, who want a better understanding of the process to apply for MPI recommendation for GACC registration under Decree No. 248. This webinar covers all types of applications for MPI recommendation - new, modification and renewal (extension). This webinar covers the following types of establishments (those that process products for export to China and require MPI recommendation for GACC registration under Decree No. 248):

establishments slaughtering, processing and storing meat
vessels and establishments processing and storing fish products (excluding live aquatic animals)
final manufacturing establishments of casings, dairy products, dairy-based infant and young children formula, bee products
final manufacturing establishments of edible fats and oils, health foods, unroasted malt, food for special dietary use (FSDU).

Note, the information in the slides was current as of March 2024 but may be subject to change without notice.

Video: Process for MPI-recommended GACC Registration (under Decree 248) (46:15)

Transcript

Webinar – Process for MPI-recommended GACC Registration (under Decree 248)

Slide 1 – Process for MPI-recommended GACC Registration (under Decree 248)

[Grace] Kia ora koutou, thanks for joining us today; welcome to our webinar about the process for MPI-recommended China registrations under Decree 248.

My name is Grace Powell, and I work in MPI’s exporter regulatory advice service team, also known as ERAS for short, and I’m joined today by my colleagues Samantha Tiller from our China Market Access team and Jack Schon from our Country Listings team.

Slide 2 – Title: What we’ll cover today

[Grace] So, what will we cover today?

We’ll start with a brief introduction where we’ll touch on some key background information, then share an overview of the MPI-recommended registration process, before going into a more detailed step by step look at the process. We’ll then talk about what happens after your application is submitted, and finish with a quick review of the resources available to help you work through registration.

Please note this webinar is only about MPI-recommended registration for China under Decree 248. If you’re not sure whether MPI-recommended registration applies to you, please watch our introductory webinar on China registration under Decree 248, as we cover that in detail there.

I’ll also note this information is up to date as of March 2024, but could be subject to change. We recommend ensuring you subscribe to MPI OMAR and FYI updates, and to keep in touch with your Chinese importers on a regular basis as things can change.

Slide 3 – Title: Introduction

Slide 4 – Title: Key definitions

[Grace] Firstly, I’ll go through some definitions of terms that we’ll be using a lot today.

So, G-A-C-C – this stands for General Administration of China Customs and can also be referred to as China Customs or GACC for short. This is the Chinese government agency that is responsible for Decree 248 and the registration process from the China side.

CIFER – this stands for China Imported Food Enterprise Registration and is China’s online registration platform that you do your registration on and that MPI also uses.

MPI registration number – this is the ID for your risk-based measure that MPI has approved. Examples are RMP (for most animal products), RCS (which is registered control scheme for things such as for fishing vessels, ULI (for dairy), or a Food Control Plan or National Programme (under the Food Act).

Slide 5 – Title: Decree 248 introduction

[Grace] So on to our introduction – this section will be fairly brief, because we already do have an introductory webinar on Decree 248 that covers all the basics of what it is, who it applies to, the labelling requirements, what CIFER is, some basic CIFER navigation and other useful information. Hopefully you’ve already watched that as your Decree 248 101, because today we’re covering some very specific parts in more detail. So please go watch that if you haven’t already.

So, in that introductory webinar we also talk about the 2 different registration methods that GACC requires you to use for Decree 248 registration. For certain product categories, you can apply for registration directly to GACC using the CIFER platform, and MPI is not involved in the process for that – we call those ‘self-registrations’. We’re not talking about those today.

The other method is generally used for what GACC considers to be higher risk categories, and this is MPI-recommended registration. This is the method we are looking at today in detail. In this method the operator has to apply to MPI first. Your information gets checked by MPI, both by email and in CIFER, and if satisfied, MPI then sends your application to GACC in CIFER.

Slide 6 - Title: MPI-recommended registration is required for these categories

[Grace] So, the product categories that require MPI-recommended registration are these ones on the screen. You’ll see we’ve split these into 2 groups, depending on if the application process that should be followed is outlined in the China OMAR or in the FYI related to Decree 248 (which is currently F36/23).

So, the products above the line are covered by a dedicated Part in the China OMAR and when exported, they’re regulated in NZ under the Animal Products Act.

So, the products under the line don’t have a dedicated Part in the China OMAR, so these follow the process outlined in F36/23. Products defined by GACC into these 4 categories are usually non-animal products processed in New Zealand under the Food Act. However, there are still a few animal products that could still fit into these categories as well which could still be processed under the Animal Products Act in New Zealand.

If you’re not sure whether your product fits into one of these categories on screen, please discuss with your Chinese importer, and you can also try using the ‘Product Type Query’ function in CIFER which we demonstrated in our other webinar.

Just be careful that these categories are based on how China defines your product, not how they are defined in New Zealand. A lot of the time they are defined in a similar way, but sometimes they aren’t. So, for example, with dairy - a dairy-based ice cream is usually classified as ‘dairy’ in New Zealand of course but China actually classifies it as a ‘frozen beverage’.

Slide 7 – Title: Types of registration applications

[Grace] So, before we get into the details of the process, we’d just like to remind you that there are different types of applications that we’ll be talking about. The process steps are the same for each type of application, but because they’re used for different purposes, there can be a few small differences in say the documents required, which we’ll mention throughout this webinar as we go through.

So, the 3 main types of applications you need to know about are:

Firstly, a new registration, also called an application for registration. This is where your establishment doesn’t have an existing registration for a product category that you want to apply to export to China, so you apply for a new registration for that category. Do remember that registration is per establishment and per product category, so you might need to have a few registrations for one establishment if you make a range of different products.

Next is a Modification. This is when your establishment already has an approved registration, but you want to change some information. This could be things like changing the establishment’s company name, process information, or adding new HS/CIQ codes and products that are within that same product category.

Finally, there’s a Renewal, where you apply to renew your registration before it expires. It’s important to note there’s a strict and limited window of time in which you can submit a renewal in CIFER, so we recommend you start working on your renewal at least 7-8 months before it is due to expire so you don’t risk missing out.

Slide 8 – Title: Overview of the process and forms

[Sam] Hi, my name is Samantha Tiller and I work in the Market Access area of MPI in the China team. I am going to go through an overview of the process and talk about what documents are required for each type of application.

Slide 9 – Title: Process for MPI recommendation

[Sam] But first let's review where you can find this process written down.

There are 2 published MPI processes that take you through the detail of the 4-step process that you need to follow to apply via MPI-recommendation, and these are very similar. Which one to use depends on the product being made for China at your establishment, and whether it has a dedicated Part in the China OMAR.

You can see which product categories sit in which document on this slide, but generally:

(On the left) For animal products that have a dedicated Part in the China OMAR, go to the China OMAR and look mainly at Schedule 1 of Part 1. But as well, look at the dedicated Parts for that product as they can have some more information about the process.
(On the right-hand side) For other products, go to the Decree 248 guidance document. The current version is called F36/23 and look mainly at Appendix One.

Slide 10 – Title: Overview of the process

[Sam] So, this is a visual overview of the process that everyone will follow. For new, for modifications and for renewals, and for all product categories where MPI-recommendation is required.

There are differences within the high-level steps that you see here, but we’ll get into those later when we take an in-depth look at the process. For now I’m just going to do a quick review of each step.

So, the first one, pre-work - this is work the operator should do before even starting the process, and includes things like making sure you understand it, and that you’re confident you know how your product is defined by China, so you know that you’re working on the right application and forms.

Step 1: This is an operator self-assessment where you do a self-audit against the China requirements to show you can meet them. At this step, you’ll also prepare some other application materials that are needed.

Step 2: Is where your verifier checks all of your application materials to confirm that they agree with your self-audit and agree that you can meet the China requirements. In most cases, this step includes an onsite audit.

Step 3: Is where the operator emails the application to MPI and attaches all the required (and verified) application materials. This is the formal request from the operator for MPI’s recommendation to GACC.

Step 4: This can only be done once you’ve been given the go-ahead from MPI, and this will be in an email. This is where you enter your application into CIFER.

From there the CIFER application will go to MPI. MPI will review it and if we are happy, we will submit it to GACC. After that, MPI will let you know about GACC’s response, and whether your application is approved or whether it needs some more work.

Slide 11 – Title: The forms and when they are required

[Sam] I’m now going to introduce the different application materials that you’ll need to prepare in Step 1. This slide shows a summary of which forms are needed, plus where there are also related documents needed as well. I will go through each of the forms one by one later on, so this is just a brief introduction to them now.

So first the China Registration Conditions form – all applications need this. These forms have been developed by GACC and there is a different one for each product category. It is effectively an audit checklist, and you will use it to do a self-audit to make sure you can meet all of China’s requirements and you’ll also gather supporting materials to back this up. When your self-audit is complete, you’ll send this form and the supporting materials to your verifier who will review everything to confirm that they agree with your assessment. Note that the supporting materials are only for you and your verifier to use for the verification step, so unless MPI asks you to, don’t send these supporting materials to MPI or put them in CIFER.

The next form along is called Manufacturer Declaration (that’s the orange one) – all applications need one of these to be signed and uploaded to CIFER. This form has been developed by GACC and there is a template that’s shared by both new and modification, and another similar template for renewal.

The next one along – the China Application form. This is only needed for new and modifications. There is a different form for each product category, and these have been developed by MPI to be an exact copy of the information that you’re going to enter into CIFER later. You don’t need one of these for renewal because in a renewal application you don’t enter any new information or any changes into CIFER. This form clarifies any attachments you’ll need to prepare for your application and these attachments get sent to your verifier as well for checking, and later on you’ll need to upload these attachments into CIFER, as GACC also wants to see them.

Next is the Modification Request Summary form, and this is only needed for modification. This just summarises all the changes you want to make to the establishment’s registration information in CIFER, and why.

Finally, (the light grey one at the end) that’s the MPI Country Listing application form, which is just the AP20(5) now and this is only needed for applications that follow the process in the China OMAR. This is an MPI form, and your verifying agency signs it when they are happy with your overall application. For the products where the application process is covered in the FYI (such as malt, health food, oil and FSDU), you don’t need one of these forms.

So, we are at the end of the general forms that you need to know about, but please also be aware that for a few select product categories such as meat, bee products and pasteurised milk, you’ll need to prepare some other forms and other related documents that GACC expects you to. Most of the time, this will be explained in the dedicated Part in the China OMAR for that product, so check there.

I’m now going to pass back to Grace to do a demonstration of where to find these forms.

Slide 12 – Title: Where to find the forms

[Grace] Hi again, so, I’m going to show you where to find all those lovely forms that Sam has just talked about. These are all on the China OMAR page on the MPI website. So, we’ll click the link, and this is what the China OMAR web page looks like – if you don’t have the link handy, just google MPI China OMAR and you should be able to find this page easily enough.

At the top you can see a section called animal products. We can click anywhere on here or the plus to expand that section and we'll see at the top a link to the China OMAR. Underneath that we also have a link to some OMAR notifications and FYIs, and in this FYI list we can find F36/23.

In the next section called processed food products we can also find FYIs, including F36/23. So, if you’re following the process in the FYI, this is the easiest way to find it.

Then we've got a section called register your food establishment for China and this is just some introductory information about Decree 248.

Finally, we have the section called Establishment registration, which is where you get your forms from. This section starts with a heading called resources, so you can find some links to handy resources to help you through the registration process, things like the guidance document Sam talked about for those following the OMAR registration process, some FAQs, links to our webinars and of course some CIFER guidance.

Underneath that we have a heading called MPI country listing application form for China and that’s where you can find a link to that AP20(5) for those people following the process in the China OMAR.

Next, we have a heading called country listings request summaries where you can find the modification request summary for those doing a modification.

Then we have our manufacturer declarations, so one version for new or modification and one version for renewals.

Finally, we come to product category headings, so there’s one for each product category and you can find the China application form and the China registration conditions for that product category. Make sure to download the right one because they are specific to the product category so you can just scroll down until you find the one you need.

Slide 13 – Title: The Process: Step by Step

[Grace] So now that you’re familiar with the forms and the steps, we’ll have a closer look at each step in the process in more detail.

Slide 14 – Title: Pre-work

[Grace] So, first of all, pre-work. This includes a few things you should do and be familiar with before you start your application.

Firstly, some reading – we recommend everyone looks through that F36/23 to get generally familiar with Decree 248. For those applying for FSDU, health food, malt, or edible fats and oils, you’ll additionally want to read the details of the process for registration covered in Appendix 1.

If you need to follow the China OMAR process for registration, make sure to read the China OMAR of course – in particular Schedule 1 of Part 1 for the process, plus the relevant parts of the China OMAR for your product as that will cover any extra requirements, and there’s also detailed guidance included in the MPI Guidance document called ‘Food China Listing Application Process’.

Second, check out CIFER. If you already have a CIFER account, make sure that you can login. If you have forgotten your password, contact MPI for help resetting it. If you haven’t got access to the category you want, contact MPI as well and if you haven’t registered the establishment in CIFER before at all (so if you don’t have any account), contact MPI to help create an account for you.

Next, and probably the most important prework you’ll do, is to know your HS/CIQ codes. These are the 13-digit codes that prescribe the exact products that you want your establishment registered to be able to make for China. If unsure about your HS/CIQ codes, talk to your importer or agent in China.

There’s 2 main reasons HS/CIQ codes are so important to get right before you start:

The first is because your Chinese importer will need to put HS/CIQ codes on their import declaration, and the ones they put must match those in your establishment’s registration in CIFER or else there are likely to be border clearance issues in China.

Second is that GACC classifies each HS/CIQ code into a product category, and you need to know which category to apply for.

When you get to the CIFER step, you’ll select HS/CIQ codes from a prescribed dropdown list for the category you’re applying for. Any HS/CIQ codes that don’t come under that category won't be available to choose.

And as we’ve covered, some product categories need to follow this MPI-recommended registration process, while others can apply through self-registration directly with GACC, and that all depends on your product category, which is based on your HS/CIQ codes.

So long story short, you definitely want to know your HS/CIQ codes and what category they fit into, so you don’t risk border clearance issues, and you don’t risk wasting a lot of time on preparing a registration before realising halfway through you’ve gone down the wrong track for your product and need to start again.

As we’ve talked about in the other Decree 248 webinar, your importer should be able to help you with these but also the ‘Product Type Query’ function on CIFER is an excellent way to check what product category each of your HS/CIQ codes come under. You could require more than one registration if you have different categories, and they could also be a mix of self-registration process and MPI-recommended registration categories.

Next, make sure to engage with your verifier and let them know you’re planning to apply for MPI-recommended China Registration. Check their availability to do the verification step (including an onsite audit where required) and keep them informed of your progress as they may be able to help clarify some of your questions. If your verifier hasn’t done a verification for China registration before, feel free to put them in touch with MPI for support.

And finally, download the forms you’ll need from the MPI website.

Slide 15 – Title: Step 1: Operator Self-assessment

[Sam] So, step 1, we’re going to go through each of the steps now, so step 1 is an operator self-assessment where you do a self-audit against the China requirements to show you can meet them. At this step, you’ll also prepare some other application materials that are needed.

So, what we’re going to do as part of this is to go through and take a closer look at each of the forms you'll need to fill out and we’ll do this on the next few slides.

Slide 16 – Title: China Registration Conditions (All applications)

[Sam] So, we’ll start with the China Registration Conditions form. You’ll need to use this one to complete a self-audit against the China requirements and these are all listed on the form.

So, start by reading the section called ‘MPI Guidance for completing the form’ (and this is usually about page 2) and this guidance explains how you should complete it.

And then you’ll work through each requirement. As you do this there are 3 main parts to complete:

First, tick whether you can conform to that requirement – which means it’s both covered in your documented systems, and it happens in reality at the establishment. Sometimes you can tick ‘Not Applicable’ if that tick box is available on the form and if that requirement isn’t applicable to your process.

Second, write a short statement on how you meet that requirement.

And third, list the filename of each of your ‘supporting material’ documents that prove that you can conform to that requirement - usually these would be documents that already exist within your documented system. It’s important to use their exact filenames so they are easily referenced if needed.

So go through and do these 3 things for each requirement to complete your self-audit.

Make sure the ‘supporting materials’ that you have identified are kept together somewhere electronically so they can easily be sent to your verifier, and in case they are requested by MPI or GACC later on.

It’s important to remember that MPI cannot submit your application to GACC if you have ticked a requirement as ‘non-conforming’. So, if you find you don’t meet one of the requirements, before you even progress to Step 2 (the verification step) you’ll need to do some work to set up and implement some new systems and procedures until you can confidently tick ‘Conform’. So, don’t move on to that next step (the verification step) until you have been able to tick ‘Conform’ for all applicable requirements.

Slide 17 – Title: Manufacturer Declaration (all applications)

[Sam] Next, we’ll talk about the manufacturer declaration. So, as we’ve mentioned before, there’s 2 versions of this form - one is used for both new and modification applications, and another one is used for renewal applications. They are actually very similar though and basically state that your establishment can meet the relevant New Zealand and China regulations. This form must be signed by your company’s legal representative, and they should only sign that after you’ve been able to complete the China Registration Conditions by ticking that you can ‘Conform’ to all the requirements.

We also recommend that you stamp this form with a company stamp or seal, as GACC generally expects this.

And a fun fact is that as part of your MPI-recommendation to GACC, MPI also has to sign a declaration that effectively declares the same thing that you’re declaring.

Slide 18 – Title: China Application Form (New/Modifications Only)

[Sam] Next is the China Application form, and remember that this is only needed for new and modification applications. There’s quite a bit of MPI guidance throughout these forms to help you understand how to fill them in.

This form reflects what is in CIFER for that particular product category and there’s generally 3 types of things you’ll need to fill in or prepare when you’re going through this form:

Firstly, there are questions that you’ll answer about the establishment and about its food safety management system.

Secondly, there are tables to fill in where you list things such as products (this is where your HS/CIQ codes come in), or where you list countries that you export the product to, or where you list tests that are done etc.

And thirdly there are attachments that you need to prepare, which will also be checked by your verifier as well as later on be uploaded into CIFER for GACC to look at.

So just as an example, one of the questions that’s always in this form is who is the establishment’s legal representative? The person that you put down is your choice to make and it’s also the person who signs the manufacturer declaration.

Another important thing to know about is one of the tables that’s in every form as well which is the ‘Product table’ and this is where you list all the HS/CIQ codes and details about each product that the establishment makes or wants to make for China (under the product category that this application is for). Note that your verifier will not have to verify the HS/CIQ codes as these are commercial pieces of information, but they will need to verify that the product description that you’ve written beside each HS/CIQ code is within the scope of the relevant risk-based measure that’s registered with MPI (for example within the scope of your RMP or within the scope of your Food Act registration).

There are 2 attachments that are commonly required for all applications that are outlined in these forms:

One is proof that the establishment is registered with MPI – for example this would be your RMP Notice of Registration that MPI Approvals had previously sent when your RMP was registered, or this could be a ULI validity statement, or it could be a Food Act registration certificate.

And the other attachment that’s commonly required for all these forms is the Manufacturer declaration which we have already talked about.

And note that some product categories also require other attachments such as process flow diagrams, certificates, site layouts etc. And this is clearly identified in each of the relevant forms.

Slide 19 – Title: Modification Request Summary (Modifications only) / MPI Country Listing application form AP20(5) (All applications following the process in the China OMAR)

[Sam] And finally our last 2 forms:

So, the Modification Request Summary (on the left of the slide) is only for modifications. So, in this one there’s 2 boxes and the top box should be completed with the required information that it outlines as it is currently shown in CIFER (so what is currently there and not what you want to change it to). Then in the bottom box is where you list row by row all the changes you want to make in CIFER, and why. As this form is sent to GACC with your application, MPI will help you to fill it out accurately. This is an Excel form and its best to keep it in this format when you send it to MPI in the next step in Step 3.

And finally in the forms (on the right-hand side of the slide) is the MPI Country Listing application form which is now the AP20(5) for all China applications and as we’ve said before this is only needed for applications following the process in the China OMAR. Your verifier signs this when they are happy with your overall application, and in most cases, they pass it onto their Team manager to endorse, with the exceptions being dairy, infant formula and bee products where the verifier only needs to sign it. This form also has a payment page to cover the MPI costs associated with processing and recommending your application to GACC.

Slide 20 – Title: Step 2: Verification

[Sam] So that’s Step 1, onto Step 2, verification. Once you are happy with all your application materials, send these to your verifier for them to review.

This step is where your verifier checks all your application materials to confirm whether they agree that you can meet the China requirements and that the evidence you have supplied to them proves this. In most cases, they will need to do an onsite audit to confirm that all of this happens in practice. Note that an onsite audit is required for most products. The exception being most general dairy products (except for pasteurised milk and infant formula which both do require an onsite audit).

This verification step can often be an iterative process where your verifier may not initially be satisfied with your application materials, and they may request more information or more proof of conformance. Verifiers should note that they’re welcome to record their comments on this form (for example they may want to record what objective evidence they saw and what they still need to see) as this version of the form doesn’t get submitted to GACC.

The verifier signs 3 forms at this step - the China Application form, the China Registration Conditions and the AP20(5) and there is an area at the bottom of each for the verifier to enter their details and sign and date. We would prefer that the verifier converts these signed forms into PDF before sending them back to the operator, and once these forms are sent back signed, this indicates that Step 2 is complete.

I’m now going to pass over to Jack from Country Listings to talk about the next steps.

Slide 21 – Title: Step 3: Request for MPI Recommendation

[Jack] Hi, I’m Jack from Country Listings, and I’ll be talking you through Steps 3 and 4.

Step 3 is when you send your official application to MPI and ask us for our recommendation to GACC. To complete this step, you’ll have to send MPI an email with all applications material attached. Read Schedule 1 of Part 1 and the associated guidance carefully so that you do get this right first time. Also note what we’d like you to include in the email title which helps us process your application more efficiently.

Include any ‘attachments’ that are required in the China Application form, but don’t send any of the ‘supporting materials’ that are linked to the China Registration Conditions unless they’re specifically requested by MPI. And an exception for infant formula operators – you shouldn’t even send the ‘attachments’ required in the China Application form as there are just too many – we will just check these once you have uploaded them into CIFER.

Slide 22 – Title: Step 4: Application in CIFER New

[Jack] And so the last step is Step 4. This is when you enter the application (that has been verified and that MPI has checked) into CIFER, and this is what GACC will see.

It’s important to not start this step until you have received an MPI email saying that you can.

This steps for this differ slightly depending on if you’re doing a New, Modification or Renewal, so we will go through each one now. If you have any questions on this when you are doing it, contact Country Listings for any help.

So, let’s just get started with the new application.

First log in to CIFER under the establishment’s user account. Often for a new registration, if that establishment hasn’t got any other GACC registrations, MPI will help to set up the CIFER user account for you.

Once you’ve logged in, click on ‘Application for registration’ from the main menu on the left-hand side. You will then see a list of product categories. Click the one that you’re applying for, and this will open a draft new application for registration that you can start working on. Remember, the China Application form you’ve prepared is based on what CIFER asks for, so all you need to do is have your verified China Application form handy, and work through entering information into the matching fields in CIFER.

A few hints we have:

- There can be some character limits in CIFER, so if some of your answers don’t fit, just do your best to add a shorter answer that matches as much as possible compared to your China Application form – check with us if you’re unsure.

- In CIFER you also fill in some tables to match the verified application form. To do this, you need to click the ‘Add’ button which will then open a pop-up box for you fill in. Once you click ‘Save’ on the pop-up box, you will see a new row of that information that you’ve just added into the table.

- Note that for uploading attachments PDF format is recommended, and you can upload more than one attachment for any field if you require so. There is a size limit of 4MB as well so sometimes if you have a large file, you will have to compress it first.

Once you’ve worked through each page (or tab) in CIFER, you’ll get a Summary table at end of CIFER application on a tab called ‘Attachment Information’ that shows the attachments you have uploaded. Note that MPI has learnt that the column called ‘Required’ (that indicates whether a certain attachment is required) isn’t always accurate so just follow your China Application form on what to upload and don’t stress if this differs. For example, Product photo often shows as ‘required’ but in most cases a photo is not required so you don’t need to upload one.

Click on preview, then review your information. Scroll to the end and click submit. Submitting sends the application to MPI not GACC.

Slide 23 – Title: Step 4: Application in CIFER Modification

[Jack] For a Modification, the steps are pretty similar to new, except you’ll click Application for Modification from the left-hand main menu.

This will show a table of all your active registrations. Click ‘modify’ on the one you want to apply to modify.

This will open up a draft modification application that’s got all your existing information on it. Work through to change the information that you are applying for, making sure that any information you change matches your verified China Application form. Upload any required attachments that have changed or that aren’t already there.

Once you’ve worked through the pages, you’ll get a summary table at end of CIFER application, and from there click preview, review your information, scroll to the end, and click submit. Submitting this sends the application to MPI in CIFER.

Slide 24 – Title: Step 4: Application in CIFER Renewal

[Jack] Finally for Renewal, as before you’ll login to CIFER and click ‘Application for extension’ on the left-hand main menu.

This will show a table of your active registrations that are within their ‘renewal window’ (the period starting 6 months before expiry and closing 3 months before expiry) you’ll see an ‘extend’ button – click on this for the registration that you are ready to renew.

This will open up a draft renewal application that will show some existing registration information (note that you can’t change any registration information in your renewal application).

A renewal application in CIFER is super quick as all you have to do is upload one document, which is your manufacturer declaration.

Once you’ve done this, you can click the blue ‘extend’ button at the top left of the screen, and then ‘confirm’ which submits your application to MPI.

Slide 25 – Title: What happens next?

[Jack] So you’ve clicked Submit in CIFER – we’ll now go through what happens next.

Slide 26 – Title: What happens next?

[Jack] Once you’ve submitted your registration to MPI in CIFER, we will review this and let you know via email whether something needs fixing, or when we have submitted your application to GACC in CIFER.

Once it’s submitted to GACC, don’t forget they still have to review and approve it. For example, for new applications, you’re not registered until GACC approves your application.

You can check on the progress of your application in CIFER using the ‘application form query’ from the main menu. You’ll see a table of any applications that you have (including those you haven’t yet submitted to MPI) so just look for the one you are interested in. There’re a few headings to look at, but the most important is the ‘Application Status’. In the example we show you on this slide you can see the application has been Approved by GACC, but there are several other statuses that could show there, which we’ll explain on the next slide.

Slide 27 – Title: Overview after submission in CIFER

[Jack] This slide shows the main ‘Application Status’ stages you may see after MPI has submitted it to GACC.

First you might see ‘Submitting to the GACC’ or ‘Waiting for Acception’ which is just a quick validation stage that GACC does to ensure that everything is there.

The status will then move to ‘Accepted’ or ‘being accepted by the GACC’ which means your application has been accepted for review by GACC. This is a good sign as it means your application is moving through the review system, but it doesn’t mean the application is approved yet.

If things have gone well, a little later you might see the status change to ‘Approved’, and that’s great, because that means GACC has approved your application and your current registration is now live, or modified with the new details, or it’s been renewed.

There are 2 other statuses that you might see which means you’ll need to do a bit more work.

One is known as ‘Returned’ which is initially shown in CIFER as ‘To be corrected by authorities’. This is shown as the orange part of the process on screen. This is when GACC returns your application in CIFER because something they have seen doesn’t make sense to them, or they want us to change something before resubmitting the application to them. Returned applications always first come back to MPI (not you) which is why it shows as ‘To be corrected by the authorities’. (with MPI as the ‘authorities’). The reason GACC returned the application can be seen by clicking a link called ‘View’ in the ‘Customs feedback’ column. MPI will review this reason and interpret what GACC wants and advise you of this via email. In some cases, we can easily make the changes ourselves and resubmit to GACC with your agreement. However, if we need you to make the change yourself, we’ll send the application back to you in CIFER, in which case the status will change to ‘To be corrected by the enterprise’ (with you as the enterprise). When this happens - click on the button in the ‘Actions’ column, adjust the information as requested and resubmit to MPI, and if we’re happy we’ll resubmit it to GACC.

The other is known as ‘Refused’ which is shown in CIFER as ‘Refused by the GACC’ This means GACC has deleted your application as it didn’t meet the requirements they expect. The reason GACC refused the application can be seen by clicking a link called ‘View’ in the ‘Customs feedback’ column. MPI will review this and interpret why GACC refused it and advise you of your options and next steps via email. If you want to re-apply and MPI agrees that you can, we’ll advise on what corrections will be required as part of your re-application. In these cases, you’ll need to start the application in CIFER again (i.e., do Step 4 again) before resubmitting it to MPI.

Slide 28 – Title: IMPORTANT: Production dates.

[Sam] So, I’m just going to talk about a couple of important things to know. First one we are going to talk about is production dates. So, once your application has been approved by GACC, that’s great. But we do want to bring your attention to an important point around when you should actually start producing the food for export to China.

If you’ve just had a new registration approved, only products made after the CIFER approval date are eligible for import into China.

If you’ve just had a modification approved where you’ve added any new products (i.e., any new HS/CIQ codes) for these new products, only those produced after the CIFER approval date are eligible for import into China. So, you can keep exporting products to China that are under HS/CIQ codes that were already in your registration, but for the new ones that you added as part of your modification these should only be produced after the CIFER approval date.

So, these 2 production date rules are hard to miss, as both GACC and MPI will notify you of these for each relevant approved application.

Slide 29 – Title: MPI listing (OMAR categories only)

[Sam] And the other thing I want to talk about is MPI listing and this is only relevant for products where the application process is outlined in the China OMAR because for these products there is also an MPI List for China. This is because there are negotiated export certificates that must be used when exporting these products to China, and if you want to apply for one of these export certificates, your establishment needs to be on the relevant MPI list.

The MPI Lists are available on the webpage called ‘List of approved products and premises’ and then you’d scroll down and look under the heading ‘China’ and there is an MPI list for each product category.

MPI manages these lists, and they reflect the GACC register. So, after GACC approves your application, MPI will update our lists to match those new details, you don’t have to take any extra steps to be added to the MPI list for these categories or for the MPI list to be updated.

And note that there are no MPI lists for the products where the application process is covered in the FYI, and this is because there are no negotiated export certificates for these products and therefore no reason to require an MPI list to manage these exports.

Slide 30 – Title: Resources

[Grace] So we’ll now talk about some resources to help you through. As you can probably tell, this process is more of a marathon than a sprint and it can take some time to work through and some parts can feel quite complex. So we do have a range of resources to help you work through that which we’ll talk about now.

Slide 31 – Title: MPI guidance and documents

[Grace] So, we did cover this earlier, but just a reminder that the China OMAR page is your landing spot for finding all the Decree 248 registration information you need, including F36/23 for everyone to read, the China OMAR and the OMAR process guidance document for those people following the process in the China OMAR.

And in the Establishment Registration section, you can download the forms you need, as well as find links to key resources including MPI’s CIFER guidance, and our webinar recordings under the resource’s subheading.

Finally, if you haven’t already, please do subscribe to the MPI email updates to make sure you don’t miss any important OMAR or FYI updates.

Slide 32 – Title: Where to find help

[Jack] If you’ve had a look through all that info and can’t quite find the answer to your question, there’s still help out there.

Our Country Listings team is happy to help with any questions you have about the MPI-recommended China registration, including about the process or any questions about an existing application that you’ve submitted to MPI.

If you’re stuck on your self-assessment, please have a chat with your verifier. For example, if you’re not sure what evidence you might need to prepare to show that you meet one of the requirements in the China Registration conditions, we recommend asking your verifier these questions as they’ll be familiar with your site and the processes, so they’re best placed to advise you.

If your verifier isn’t sure, or has any questions themselves, please ask them to contact our China Country Listings team for help.

Slide 33 – Title: Thank you!

[Grace] And that brings us to the end of the webinar today, thank you everyone for joining us, we hope you’ve found this helpful.

[End of transcript]

Download Process for MPI-recommended GACC Registration (under Decree 248) [PDF, 2.6 MB]

Check export requirements when watching the webinar resources

As well as meeting New Zealand standards and requirements, you may need to meet specific New Zealand export requirements depending on your product and the destination country. These are some key documents to read and refer to when watching the webinar resources.

Export requirements

Find out how to export goods from New Zealand to other countries. Check the exporting requirements for food and beverages, timber and wood products, animals, ACVMs, and other products.

Export requirements

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Any requirements for the export of animal products to a specific country or market are outlined in OMARs. These documents are password protected, so you will need to apply for a password.

Overseas market access requirements

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Disclaimer

The information provided is by way of general guidance and does not constitute legal or technical advice. We recommend you seek independent legal advice for specific situations.

While MPI has taken all reasonable care in the compilation of these resources, it does not accept responsibility or liability to any person for any errors in these resources or the consequences of any reliance placed on the information contained within them.

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If you have questions about exporting primary products, email exporterhelp@mpi.govt.nz

About the webinars

China Registration of Food Manufacturing Establishments (Decree 248)

Topics covered

Video: China Registration of Food Manufacturing Establishments (Decree 248) (34.34)

Process for MPI-recommended GACC Registration (under Decree 248)

Topics covered

Video: Process for MPI-recommended GACC Registration (under Decree 248) (46:15)

Check export requirements when watching the webinar resources

Export requirements

Overseas market access requirements (OMARs)

Get the latest updates

Disclaimer

Who to contact

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