China: Dairy, Seafood, Honey and Other Edible Non-prescribed Goods: General Administration of Customs of the People's Republic of China (GACC) Decree 280 - update to overseas enterprise registration requirements

Date of issue: 3 June 2026
Date of effect: 1 June 2026 to until further notice
Reference Number: MAA 2026-11

Attention

• Industries—Industry bodies – Dairy Australia – Infant Nutrition Council, Dairy Export Industry Consultative Committee, Seafood Industry Australia, Seafood Trade Advisory Group, Seafood Export Consultative Committee, Australian Honey Bee Industry Council, Australian Food and Grocery Council
• Export dairy, seafood, honey and edible NPG establishments
• Exporters
• Department of Agriculture, Fisheries and Forestry — Central and Regional offices

Purpose

This Market Access Advice (MAA) provides food business operators and exporters with information regarding upcoming changes to China listing requirements. As of 1 June 2026, Decree 280, the Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food will replace Decree 248 (of the same name).

Decree 280 – update to overseas enterprise registration requirements

The updated requirements will apply to new applications, amendments, and renewals submitted through the China Import Food Enterprise Registration (CIFER) system from 1 June 2026. Existing registrations remain valid. Establishments are not required to take immediate action at this time.

A summary of updates is provided below:

• Article 6: Replacement of the fixed list of 18 product categories with a risk-based catalogue of imported foods requiring official recommendation.
  • The catalogue was published in GACC Announcement 27 on 24 March 2026 (Attachment A).
  • The new catalogue consists of 17 categories:
    • meat and meat products, casings, bird's nests and bird's nest products, bee products, eggs and egg products, edible fats and oils, stuffed wheaten food, edible grains, grain flour and malt, dehydrated vegetables, seasoning powder, nuts and seeds, dried fruits, special dietary foods, health foods/dietary supplements, dairy products, and aquatic products.
• Article 8-9 and 17-18: Streamlining of the registration process for countries with food safety systems recognised by GACC, or established cooperation agreements.
  • Enterprises may submit registration application documents to GACC directly or via an authorised agent.
  • Audit and inspection reports and competent authority recommendation letters continue to be required for products listed in the catalogue.
  • Article 17-18 also provide for a government-to-government list registration method to be applied in certain circumstances. The department is seeking further clarification from GACC on how this mechanism will operate and whether it will be applicable to Australian establishments.
• Article 20: Changes to registered enterprise information will no longer require reapplication if the changes do not significantly impact food safety or hygiene management.
  • Establishments must submit a modification application to update their listings.
• Article 21 and 22: Registrations will have a duration of 5 years. Eligible registrations will also undergo automatic renewal for a further 5 years upon expiry.
  • Meat and meat products and bird's nests and bird's nests products are ineligible for automatic registration renewal.
  • Applications for products excluded from automatic renewal must be submitted within 3-12 months prior to the expiry of registration.
  • Automatic renewal does not apply in certain circumstances, including where establishments are suspended or subject to regulatory actions.
• Article 27: Decree 280 expands the grounds for revocation of registration from seven to nine circumstances. Additional grounds include where an enterprise does not meet registration qualifications or conditions, and other circumstances in which registration may be revoked in accordance with law.
• Article 30: Conditions for overseas storage facilities subject to registration and management will be separately announced by GACC.
  • In Announcement 27, GACC advises the scope of overseas storage facilities for imported food that requires registration includes cold storage facilities used for the storage of food of terrestrial animal origin and aquatic products (does not include establishments handling dairy products).

The department will continue to engage with GACC and provide further advice as more information is received. GACC has indicated that additional implementation guidance and supporting materials will be released following commencement of Decree 280. The department will review any further guidance and provide further updates as information becomes available.

All exporters are encouraged to review the Manual of Importing Country Requirements (Micor) and work with their importers to ensure that their products comply with China's import requirements.

Further information

Contact ExportStandards@aff.gov.au if you have any queries.

The information provided above is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive. The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice. Exporters are encouraged to verify these details with their importers prior to undertaking production/exports. The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.