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. It remains unclear whether this decree applies to apple, pear, and cherry packers.
Caution is advised if you are planning to ship to China for arrival in January. There is the potential for delays on arrival given the uncertainty associated with Decree 248.
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 has not provided guidance to confirm or deny that fresh fruit packers are subject to Decree 248.
On 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. This USTR interpretation has not been confirmed by China.
For products that may require self-registration (such as fresh fruits), the GACC registration website portal came online November 3. The portal is in Chinese and still in the building process; users trying to use the portal report that they are often unable to complete the registration due to portal malfunctions. FAS Beijing produced an unofficial self-registration guide for overseas facilities published in FAS GAIN report CH2021-135 located here. Packers may want to consider this option.
USTR and FAS continue to press GACC for clarification on registration requirements and further updates will be provided as new information 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. As recently as October 2021, FAS guidance was that apple, pear, and cherry packing facilities should be exempted under Article 11 of the Decree as all packers are registered annually with GACC through USDA Animal and Plant Health and Inspection Service (APHIS). At present, FAS is directing packers to contact GACC representatives directly for information.
FAS GAIN report CH2021-135 (published November 10) provides guidance for those who may contemplate registering with GACC.