Renewing GACC registration (General Administration of Customs of China) is crucial for continuing your food and beverage exports to China. Here’s a practical guide to help you through the process, although the specifics will vary according to the nature of your business.
You can check the expiry of your existing registration using the CIFER system here.
You can find my blog post about the original registration process here. Since 2022, ALL overseas food and beverage manufacturers have to register their products in the Chinese system before they are able to import.
For “riskier” products a similar system was already in place from 2018 onwards and as the initial certificate is valid for 5 years, the first major group of producers have just had to learn about GACC registration renewal requirements.
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The General Process to renew GACC Registration Online
Renewing GACC registration (General Administration of Customs of the People’s Republic of China) involves in general several steps:
- Prepare the necessary documents: These typically include your business license, tax registration certificate, organisation code certificate, and other relevant documents as well as your existing registration number.
- Application: Submit your application to the GACC. This can usually be done online through their official website.
- Review: The GACC will review your application. This process can take several weeks even though it officially should be faster.
- Approval: Once your application is approved, you will receive a new registration certificate.
Please note that the specific requirements and process may vary depending on your location and the nature of your business. It’s recommended to check the GACC’s official website or contact them directly for the most accurate up to date information.
You can find a list of all the registered food exporters here.
GACC class I Renewal – Registration Regulations for Overseas Food Manufacturers
This class of products is the simplest to renew.
- vegetable products eg canned, processed
- grains (need to check what is GACC II)
- other beverages
- biscuits, cakes & bread
- confectionary, chocolate
- roasted coffee or cocoa beans
- fruit products
- most other kinds of processed or canned foods
You can fill in the application form here for the annual renewal, pay the fee of $150-$300 and wait 7-10 working days for the extension of your certification.
Remember that China and the EU have slight differences on the HS codes which they use – see the example below.
Also, make sure that any documents that you submit for the renewal are still valid and not expired.
GACC II Renewal (medium risk categories)
This includes the following product groups:
- natural casings for sausages
- bee products and honey
- egg products
- edible fats & oils
- stuffed pastry products (or skins for eg dumplings)
- edible grains
- fresh & dehydrated vegetables, dried beans
- unroasted coffee beans
- plant spices
- nuts & seeds
- dried fruits
- special dietary foods (eg sports nutrition, complementary foods for babies/young children)
- food with special health claims
GACC III (high risk products)
This includes products such as:
- infant formula
- aquatic products
For both medium and high risk products, you need the confirmation of the competent local authorities in your home country to be able to register, modify or renew your registrations.
Renewing your GACC Registration in China for Medium or High Risk Products
Establishment registration in the CIFER system I mentioned above are normally valid for a period of 5 years and you need to start the renewal process in the system between 3 & 6 months prior to expiry (the option is ONLY available in this time window). After that time, the “renewal button” will no longer be available in the system and you will probably have to start from the beginning again with a new registration. This will undoubtedly mean also a period where you are not able to export.
Contact your local authorities once you’ve submitted an “application for extension”.
GACC has stated that all establishments that were registered in CIFER by GACC (ie did not self-register in CIFER after January 1, 2022 because they already were part of a mandated process), must update their registrations in CIFER with an “Application for modification”, prior to completing the renewal process via an “Application for extension”.
Renewing GACC registration is supposed to be quite fast but if there are a lot of applications submitted at a similar time then it can take several weeks longer than anticipated to receive your new registration. If your existing registration expires in the meantime, that can leave you unable to import so make sure that you keep a close eye on this.
The “Application for modification” must be approved by GACC before an “Application for extension” can be submitted. Regardless of registration expiry date, all establishments registered by GACC in CIFER (that is, did not self-register in CIFER), must update their registrations in CIFER by submitting an “Application for modification” as soon as possible in 2023. This includes all “medium risk” establishments with expiry dates in 2026 and 2027.
- download the declaration form from the CIFER application page
- add both the enterprise name and China registration number to the first blank line in the declaration
- make sure the enterprise name is entered exactly as it is entered in the CIFER application
- both name and position of the legal representative have been provided in the designated location – this is the person who has to sign all the documents (& take liability for them being correct)
- the declaration has been signed by the legal representative identified in the application
- a fully legible/visible company stamp/seal has been applied
- you have completed and uploaded the original GACC template provided in the application
As with the original application make sure that
- the address of the entreprise is the physical location (not a P.O.Box) & matches the supporting documents (& the stamp used!)
- the HS codes of the products are correct according to the Chinese customs’ requirements
- the products listed (especially fish/seafood/meat) match exactly the items approved for your geography – for fish you might need to include the latin names as well
Once the declaration has been uploaded to the application, click the “Extend” button in the top left corner of the screen to submit the application to your local authorities for review/approval (they are linked in the system to your account) and take a screenshot of the status. It should say “Current state: Submit to Authorities” if your application process was successful.
You should then email your relevant authorities, including your enterprise full name, the registration number of the enterprise (as it appears in the CIFER system) & a copy of the screenshot that you’ve submitted the application for renewal.
You will then have a product specific set of additional documents (there is a GACC checklist) to supply whilst your local authorities are checking your submission. Make sure when you submit those documents that
- they are clearly signed by the same legal representative as in the main application on each page
- each page is clearly stamped
- the document (checklist) is submitted in pdf form with a file size of less than 4MB to your local authorities
You need to closely monitor the status of your application in the CIFER system once your local authorities have approved it as there may be a request for additional information or signatures and/or stamps could be missing somewhere.
Recommendations for renewing GACC Registration
GACC themselves strongly recommend that applicants register directly and don’t leave this application process to their importer or distributor. Importers require your registration number to complete China customs clearance. Should you change your distributor, or have multiple distributors, they may be reluctant to share your registration number and authorisation password if your circumstances change. The authorisation password will be the only credential when you enter the GACC system to go through customs clearance procedures in China so it’s important to know what it is.
The China customs management system application form is currently only available in Mandarin. For overseas enterprises without a branch in China, GACC prepared an English version of the application form, including detailed instructions and guidance for each application step (to help overseas food manufacturer and processing plant companies who wish to register for themselves). It’s not always immediately apparent what’s required but if you’re just looking to renew your original certificate this should be fairly easy to do.
One of the main issues with this process is if not all of your documents conform and match one another – this is especially true with addresses, signatures and stamps. any variations will be rejected by the Chinese authorities.
For the renewal of medium or high risk products it can take weeks or even a couple of months for the authorities to give you their feedback so make sure that you begin to prepare in good time. There are a number of agencies out there who are specialised on this process and who are able to actively communicate with the authorities to ensure that any open questions can be rapidly clarified.
This post is simply for information purposes to help you understand what is required and you should always check the most up to date requirements with your local authorities or directly with GACC. If you’d like me to recommend you an agency, book an international clarity call at the link in the paragraph below.
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