Northwest Horticultural Council
China Implements New Registration Requirement for Exporters
Current situation: The General Administration of Customs of the People’s Republic of China (GACC) issued Regulations on the Registration and Administration of Overseas Producers of Imported Food (Decree 248) that is scheduled to enter into force on January 1, 2022.
This decree does not apply to U.S. apple, pear, and cherry packers.
December 1, 2021, the USDA Foreign Agricultural Service (FAS) published GAIN Report CH2021-0143 with updated Decree 248 information stating verbal confirmation that “Fresh fruit producers do not need to register or label registration numbers on packages,” and is located here.
USTR and FAS will continue to provide updated information as it is received.
Background: Northwest Horticultural Council discussions with FAS began in 2020 regarding China’s intent to require registration of overseas production facilities. Decree 248 was published April 12, 2021.
Over the past year, the United States Trade Representative (USTR) and USDA Foreign Agricultural Service (FAS) have sought clarification on the registration process for the produce industry. GACC was slow to provide guidance and to confirm or deny that fresh fruit packers are subject to Decree 248.
November 10, FAS published GAIN Report CH2021-135 entitled Decree 248 Unofficial Self-Registration Guide for Overseas Food Facilities that provided guidance on how to self-register using the GACC website and is located here.
November 16, USTR reiterated its current interpretation that, according to Decree 248 Article 11, apple, pear, and cherry packers are exempt from this new registration process as they are already registered with GACC per phytosanitary work plan requirements.
December 1, FAS also published GAIN Report CH2021-0150 entitled Decree 248 HS Codes Published in GACC Single Window and is located here. HS codes for fresh apple, pear, and cherry fruits are not included in the list of items covered by Decree 248.