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What should we know when exporting Pet food to China?

 

With the upgrading of pet market consumptions, imported pet food has been hot pursuit by domestic consumers in recent years. And the import volume has been increasing year after year.

I. What is pet food?

Pursuant to the “Supervision and Management Measures for the Inspection and Quarantine of Import and Export Feed and Feed Additive”, issued by General Administration of China Customs (hereafter referred as GACC), Article 69: feed refers to the products and raw materials that are planted, bred, processed and produced to feed the animals. It includes bait-purpose animals, feed-purpose (including bait purpose) refrigerated fresh animal products and aquatic products, processed animal protein and grease, pet food and dog chews, forage grass, silage, cereal feed, chaff cake, dregs, processed plant protein and plant powder, compound feed and premixed additive feed, etc.

Pursuant to the “Administrative Measures for Petfood”, issued by Ministry of Agriculture and Rural Affairs of China (hereafter referred as MARA), Petfood refers to is the product made with industrialized processed ingredient(s), for pet dog and pet cat, including compound pet food, additive premix pet food and other pet food.

From the definitions by GACC and MARA, it is different from human food. Pet food belongs to feed category in commodity classification.


II. General procedure and requirement by GACC for imported pet food

Pursuant to the “Supervision and Management Measures for the Inspection and Quarantine of Import and Export Feed and Feed Additive”, General Administration of China Customs implements the registration system on pet food producers from the countries and regions approved for pet food import. The imported pet food shall come from the registered overseas producers. GACC is responsible for approving market access applications for pet food to be exported to China for the first time and registering all overseas pet food manufacturing facilities that export to China. All pet food producers shall be complied with GACC quarantine requirement.

2.1 Accepting application request from exporting countries/regions.

The official quarantine/inspection authority of the exporting country shall, according to the trade interest, submit the applicant enterprise documentations to GACC for exporting pet food products to China. After receiving the application, GACC will conduct primary evaluation, on the basis of China regulations and technical standards on applications. GACC will deliver a questionnaire concerning the Import Risk Analysis (IRA) to the exporting country for reply if primary evaluation is positive. The questionnaire mainly includes laws and regulations systems, animal pandemic monitoring, capability of safety & health control and etc.

2.2 Conducting evaluations on applications

GACC will organize the relevant specialist to risk analysis evaluation on questionnaire and other technical document. If necessary, GACC may ask the exporting country for more information during the evaluation period or conduct site inspection, in purpose of all information and procedures related to applications are genuine and consistent.

2.3 Negotiating the inspection and quarantine requirement.

Based on the evaluation results, GACC and exporting country authority will discuss quarantine and hygiene requirements for pet food exported to China. When 2 sides reach agreement on the foresaid requirement, they will make affirmation on inspection and quarantine requirements (including the requirements by signing inspection & quarantine protocol, memorandum and announcement), content & format of the related certificate and exporting country/region veterinary officer details.

2.4 Registering applicant enterprises.

The overseas pet food producer shall comply with the requirements stipulated in relevant laws and regulations of the exporting countries or regions and, in the meantime, accord with equal requirements stated in relevant Chinese laws and regulations as well as standards. After being approved in the examination held by the competent authorities in the exporting countries and regions, the overseas producers can be recommend to GACC by the foresaid authorities.

GACC shall examine and audit the aforesaid recommend documents and decide if site inspection is necessary based on risk analysis.

As to the unqualified documents, GACC shall notify the competent authorities of the exporting countries or regions to rectify or supplement them.

As to the qualified documents, after consulting with the competent authorities of the exporting countries or regions, GACC shall designate experts to the exporting countries or regions to inspect the supervision and management systems on pet food safety and carry out spot check on the enterprises that apply for the registration in China. Enterprises that disqualify in the spot check shall not be registered in China and GACC shall notify relevant reasons to the competent authorities of the exporting countries or region; enterprises that qualify in the spot check or other recommended enterprises that have not undergone the spot check shall be registered in China, and GACC shall announce relevant information on its official website. Registered enterprises details are available on GACC official website (List of registered pet food manufacturing and processing enterprises abroad).

2.5 Quarantine Permit

Before importing, the importers in China shall apply Entry Animals and Plants Quarantine Permit and make import registrations from importing area local custom authority.

III. Requirements from Ministry of Agriculture and Rural Affairs of China


Apart from GACC factory registrations, the exporting enterprises shall also need to apply register license from MARA.

According to MARA regulations (Administrative Measures for Petfood), the overseas enterprise shall obtain the import registration license, through a China based company, for pet food before exporting to China for the first time. Compound pet food and additive premix pet food are mandatorily required for registration license. Other dog food is not mandatory, like treats, dog chew. For those imported pet food without MARA register license shall not be sold and circulated in China.

In the meantime, pet food which are exported to China shall include a Chinese label with full regulatory compliance to “Regulation on Pet Food Label”; The hygienic indicators of the products shall meet the requirements of the “Regulation on Pet food Hygienic”; Compound and additive premix pet food shall comply with the standards and requirements when doing MARA registrations. All ingredients and feed additive in pet food shall comply with MARA regulations.

IV. GACC approved countries and regions for pet food.

There are 20 GACC approved countries/regions which are allowed to export their pet food products to China: Netherlands, France, Belgium, Germany, Denmark, Czech Republic, Italy, United States, Canada, Brazil, Argentina, New Zealand, Australia, Austria, Spain, Thailand, Taiwan, Philippines, Uzbekistan, and Kyrgyzstan

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