What is the GAC registration for imported food in China?

GAC registration — formally GACC Decree 248 registration under the General Administration of Customs of China (海关总署, Hǎiguān Zǒngshǔ, formerly GAC) — is a mandatory pre-export registration that every overseas food manufacturer must complete before their products can be legally imported into China. Established by the Administrative Provisions on Registration of Overseas Manufacturers of Imported Food (进口食品境外生产企业注册管理规定, GACC Decree 248, effective January 1, 2022), this system requires all overseas food production facilities that export to China to register with GACC. Over 1.8 million import food batches were declared at Chinese ports in 2024 (GACC data), and every batch originated from a GACC-registered overseas manufacturer. Without valid registration, the manufacturer’s products are automatically detained at the port of entry and cannot proceed through customs clearance. Registration is valid for 5 years and must be renewed before expiry.

The Two Registration Tracks Under GACC Decree 248

Decree 248 establishes two separate registration tracks based on the risk level of the food product. Understanding which track applies to your product is the first and most important step:

The 18 high-risk categories requiring GACC-verified registration (Track 1) are: meat and meat products, aquatic products, dairy products, bird’s nest products, edible bird’s nest, bee products, eggs and egg products, edible oils and fats, stuffed flour-based foods (e.g., frozen dumplings, buns), grains (milled), sugar and confectionery products (certain categories), beverages and alcoholic beverages (certain categories), processed nuts and seeds, dried fruits and vegetables, infant formula and young child formula, health foods (保健食品), special dietary foods, and frozen desserts (ice cream, etc.).

Track 2: Self-Registration via the CIFER System

For the majority of foreign food manufacturers — those producing low-risk products like confectionery, chocolate, cookies, biscuits, snacks, seasonings, sauces, tea, coffee, pasta, noodles, and most prepackaged foods — self-registration via the China Import Food Enterprise Registration (CIFER) system is the applicable pathway.

The self-registration process involves the following steps:

1. Create a CIFER account — Access the CIFER online portal (cifer.singlewindow.cn) and register as an overseas enterprise. The system supports multiple languages including English.
2. Complete the registration form — Submit the manufacturer’s legal name, facility address, contact information, product categories, production capacity, and food safety management system certification details. All fields must be completed in both English and Chinese.
3. Upload supporting documents — Provide: business license or equivalent registration certificate from the home country; food safety management system certification (e.g., ISO 22000, HACCP, FSSC 22000, or equivalent); facility layout and production process description; and a declaration of compliance with PRC food safety standards (a signed undertaking that products comply with applicable GB standards).
4. Submit and receive registration number — The system processes the submission and issues a unique 18-digit registration number (format: 5100/XXXXX) within 1–2 weeks. This number must appear on all export documentation and product labels.
5. Maintain the registration — Notify GACC of any changes in facility name, address, production scope, or food safety management certification within 30 days. Renewal application starts 3–6 months before the 5-year expiry.

The CIFER system does not require a Chinese entity or a Chinese agent for submission, making it accessible for foreign manufacturers to handle directly. However, many brands engage a Chinese customs broker or food safety consultant to ensure accurate completion, especially for the Chinese-language portions of the registration.

Track 1: GACC-Verified Registration for High-Risk Categories

Manufacturers of products in the 18 high-risk categories face a more rigorous process. In addition to the documentation required for self-registration, Track 1 requires:

• Application through the competent authority — In most cases, the application is submitted through the food safety authority of the manufacturer’s home country, which then recommends the facility to GACC. This country-to-country channel is the primary pathway.
• GACC on-site inspection — GACC officials (or authorized third-party auditors) conduct a physical inspection of the manufacturing facility. The inspection evaluates: facility hygiene, production processes, raw material sourcing, quality control systems, laboratory testing capabilities, and recall procedures. Inspection reports are submitted to GACC headquarters for approval.
• Extended processing timeline — From initial application to registration issuance, Track 1 typically takes 3–12 months. The timeline depends on: the home country authority’s processing speed, GACC’s inspection scheduling (inspections are often batched by country), and the facility’s readiness for inspection.
• Registration with product scope limitations — The registration specifies the exact product categories approved, and any expansion requires a new application. A dairy facility registered for “milk powder” cannot export “cheese” under the same registration.

As of 2025, GACC had registered approximately 15,000 overseas food facilities under the high-risk Track 1 pathway, with the largest numbers from the EU, US, Australia, New Zealand, and Brazil. The on-site inspection bottleneck is a well-known challenge — in 2024, GACC conducted approximately 400 on-site inspections of overseas facilities, meaning the average wait for an inspection slot can be 6–12 months for new applications from countries with many applicants.

Labeling Requirements Linked to GACC Registration

GACC registration is intimately linked with China’s food labeling requirements. Under Food Safety Law Article 97, all imported prepackaged food must have Chinese-language labels affixed before or at the port of entry. The labels must include:

Approximately 40% of import food shipment rejections are related to labeling errors, making label compliance the single most common reason for customs detention. Foreign manufacturers should invest in a pre-shipment label review by a China food regulatory specialist before the first export shipment.

Port Inspection Procedures After Registration

Even after GACC registration is obtained, each import batch undergoes port inspection. The two-phase system works as follows:

• Phase 1: Document Review — Customs reviews the import declaration, invoice, packing list, bill of lading, health certificate from the exporting country’s competent authority, and GACC registration certificate.
• Phase 2: Physical Inspection and Testing — Based on risk category, the shipment is selected for inspection. Low-risk products (confectionery, beverages) have 1–5% sampling rates; medium-risk (packaged foods, seasonings) 10–30%; high-risk (meat, dairy, infant formula) 30–100% with mandatory laboratory testing. Port clearance typically takes 1–15 days depending on the risk category.

Shanghai handles approximately 30% of China’s food imports and is known for the fastest clearance times (2–5 days for low-risk). Tianjin is a major port for meat and dairy with stricter inspection rates, while Shenzhen is the key port for cross-border e-commerce food imports. Products that fail inspection are detained (扣留, kòuliú) and may be ordered destroyed, returned, or re-exported depending on the nature of the violation.

Registration Renewal and Maintenance

GACC Decree 248 registration is valid for 5 years from the date of issuance. Renewal applications should be submitted 3–6 months before the expiry date. A lapsed registration means the next port shipment is automatically detained — there is no grace period. Manufacturers must also promptly notify GACC of any changes to facility name, address, production scope, or food safety management certification. Failure to update within 30 days can result in suspension of the registration. GACC registration lists are updated monthly on the GACC website; manufacturers should verify their registration status at least quarterly, especially during renewal periods.

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What Is the GAC Registration for Imported Food in China? — first published on China Gateway 360. Last updated: July 2026.

Compliance Maintenance Between Registrations

Maintaining GACC registration compliance is an ongoing obligation. GACC conducts periodic reviews of registered overseas facilities, and manufacturers must maintain complete traceability documentation for all products exported to China. Under Food Safety Law Article 53, importers must establish a full traceability system recording supplier details, batch numbers, quantities, and shelf life. The Chinese importer of record must maintain these records for at least 2 years after the product’s shelf life expiry – meaning records for a product with a 2-year shelf life must be kept for 4 years total. GACC can suspend or revoke registration if products fail port inspections repeatedly – approximately 120 overseas facilities had registrations suspended in 2024. Foreign manufacturers should implement a quarterly self-audit covering facility hygiene, production records, batch traceability, and label compliance. Changes to the manufacturing facility must be reported to GACC within 30 days, including name changes, address changes, production line reconfiguration, or certification updates.

Common Pitfalls in GACC Registration

Foreign food manufacturers frequently encounter several avoidable pitfalls. The most common is confusing GACC Decree 248 (manufacturer registration) with Decree 249 (importer record-filing) – completing one but not the other results in port detention. Another frequent error is misclassifying products – approximately 15% of first-time GACC applications are rejected due to incorrect product category classification, incomplete documentation, missing Chinese translations, or expired business license copies. A pre-submission review by a China food regulatory specialist can reduce processing time by 4-6 weeks. The third major pitfall is failing to track the 5-year renewal cycle – registration expiry is not automatically notified, and a lapsed registration means automatic detention of the next shipment with no grace period. Label compliance is the leading cause of shipment rejections (approximately 40% of all rejections), making pre-shipment label review by a China regulatory specialist an essential investment before the first export shipment.