Withdrawal of Mandatory Food Label Filling Requirements for Imported Pre-Packaged Food Items: Cause for Celebration or Added Pressure on Businesses to Get Things Right?

Towards the end of April 2019, Chinese custom officials announced the withdrawal  of the mandatory label filling for imported pre-packaged food items. This means that from 1st October 2019, both importers and customs brokers will no longer have to submit documentation in relation to China customs product labelling document which includes Chinese labels for imported pre-packaged food products during importation.

This withdrawal of mandatory label filling will result in a vast improvement of efficiency during customs clearance which means less bureaucratic paperwork and also speeds up the process for businesses wishing to enter the market.

However, it is important to note that for some ports, Chinese customs officials may still require importers to provide labelling documentation for successful customs clearance. Therefore, it is extremely important that both importers and custom brokers understand specific requirements of the port in which they are operating from in greater detail to avoid any unnecessary details or penalties.

It will be the sole responsibility of the importer to review whether the Chinese label of the imported pre-packaged food meets the requirements of relevant GB standards.

In addition, importers may experience random on-site inspections by customs or laboratory testing officials who will require to be provided with the relevant compliant labelling documents that include Chinese labels and other supporting evidence.

If any complaints are received by customs officials in relation to violations of food safety, labelling or any other GB regulations, Customs shall investigate and once the investigation is complete, they will act in accordance with the law such as administering penalties or requesting full product recalls.

Mette Knudsen, CEO of regulatory and compliance consultancy firm Knudsen&CRC commented on how “it has become easier in some respects and it has become far more complicated in others. Previously you could be denied access to China by not having your paperwork and labelling in place. With the new laws that were published in April and will come into effect this autumn, as long as you have your documentation and labelling in place, you will be allowed into the market without inspection. However, obviously if you are taken out for random inspection on the market and you don’t have your documentation in place you may be asked to recall all your products. So is it easier today, yes, it may be easier to come across the boarder but when you come on the market it is definitely not easier.”

Ms Knudsen further commented on how “the market in China is changing now so you will not only see the government looking into non-compliant products but also their professional consumers. There is a reward as a professional consumer that you will actually be rewarded ten times the purchasing price of the product if you find a non-compliant product being sold.”

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