China Sets Requirements for Imported Food Not Regulated by National Standards

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March 5, 2020 - Xiaolu Wang

The China National Center for Food Safety Risk Assessment (CFSA) issued the Notice on the Technical Review of Relevant Standards Applicable to Imported Food Products Not Subject to National Food Safety Standards (关于进口尚无食品安全国家标准食品相关标准技术审查工作的通知) (the Notice) on 18 January 2020. The notice provides detailed instructions on the application procedures and required application documents for the technical review of foreign or international standards with which imported food products comply, provided that no Chinese National Food Safety Standards apply to these products.

Verisk 3E Review            

Specifically, the notice regulates food products that are manufactured outside of China and are not regulated under any Chinese National Food Safety Standards (concerned products). The following food products are excluded from the scope of this application:

  • Food products that are regulated under general food safety standards. Examples of these general food safety standards include:
    • National Food Safety Standard of Maximum Levels of Mycotoxin in Foods (GB 2761)
    • National Food Safety Standard for Maximum Levels of Contaminants in Foods (GB 2762)
    • National Food Safety Standard - Maximum Residue Limits (MRL) for Pesticides in Foods (GB 2763)
    • National Food Safety Standard of Pathogen Limits for Food (GB 29921)
    • National Food Safety Standard for Food Additive Use (GB2760)
    • National Food Safety Standard General Rules for the Labeling of Prepackaged Foods (GB 7718)
  • Food products that have been specifically approved by Chinese authorities
  • Food products that are mixtures of food ingredients that are regulated under applicable Chinese National Food Safety Standards

To import a concerned product, the exporter, foreign manufacturer or Chinese importer must submit an application to the China National Center for Food Safety Risk Assessment (CFSA) to review the technical standards with which the concerned product complies. The notice further specifies the required application documents for this review and outlines the general workflow of the review process.

Required Application Documents

The following documents must be submitted as part of the application package:

  • Application form
  • Proof that the concerned product is permitted in a jurisdiction(s) outside of China, such as a Certificate of Free Sale. This proof must be issued by a government authority or entities designated by the national competent authorities
  • Technical standards or regulations that are applicable to the concerned product in a foreign jurisdiction. International standards are also acceptable
  • Supporting information of the applicability of the foreign technical standard, regulation or international standard to the concerned product, such as product ingredient information, information on the production techniques used and information on risk assessments conducted in accordance with the identified regulations or standards
  • Picture and label of the concerned product
  • Texts of applicable regulations or standards
  • Product sample (one sample contained in the innermost packaging of the product or one sample of 30 grams by weight)

Please note that all supporting documents as required above must be presented in Chinese or be accompanied by a Chinese translation. Applicants may indicate information that they would like to designate as confidential business information in their applications.

Application Procedures

In addition to the required application documents, the notice outlines the workflow of the technical review. Specifically, the review will be conducted in the following steps:

  • Submission of application. Applications can be submitted via CFSA's website
  • Format review. Confirms the completeness of an application
  • Initial content review. Confirms that there are no Chinese National Food Safety Standards applicable to the concerned product
  • 30-day public consultation. During which time the CFSA will publish on its website the applicable foreign or international standards/regulations for the concerned product, as submitted by the applicant. The public will have 30 days to review this information and submit their comments to the CFSA.
  • Technical review. Will be conducted by food safety experts from relevant ministries
  • Issuance of review decisions. No specific timeline for completing this review has been identified in the notice

Analysis              

Companies that manufacture food products or import these products into China should note that the CFSA recently published a notice that provides detailed instructions on the process of technical review of applicable standards and regulations for food products that are not specifically regulated under a Chinese standard. Affected parties need to review the notice and follow the instructions when applying for this technical review.








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