China's General Administration of Customs (GACC) will begin full enforcement of Decree No. 280 — the new Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food — on June 1, 2026. The decree was promulgated on October 14, 2025, and its implementation details were released through GACC Announcement No. 27 of 2026 on March 18, 2026. On the effective date, the long-standing Decree No. 248 (in force since April 2021) is repealed.

For any company that exports food into China — or that sources finished food products from overseas suppliers for the China market — this is the most consequential change to the registration regime in five years. Here is what is changing and what you should check before the deadline.

From Two Tracks to One Application

Under the old Decree No. 248, overseas manufacturers reached the registration system through one of two routes: recommendation by their home-country competent authority, or self-registration. Decree No. 280 merges these into a single application pathway. Every overseas manufacturer now files in its own name through the CIFER system (China Import Food Enterprise Registration), regardless of product category.

Whether a product still needs an official recommendation from the home-country authority before that application now depends on a risk-based product catalogue rather than a fixed product list. GACC assesses categories by raw material, processing method, and food-safety data, and the catalogue is subject to dynamic management — meaning it can be updated as GACC adjusts its risk view. The starting catalogue is the baseline, not a permanent fixed state.

Expanded Scope: Cold Storage Now Included

Decree No. 280 brings overseas cold storage facilities into scope for the first time, where the facility stores land-animal-sourced foods or aquatic products. Operators of qualifying cold stores must register through CIFER ahead of the June 1 deadline. Facilities storing only other food categories are not currently caught, but operators should verify their specific product categories against the catalogue rather than assume.

Renewals and the GACC Number on Packaging

Two practical changes matter for ongoing compliance:

  • Automatic renewal for most categories. Registrations expiring after June 1, 2026 will, in most cases, be automatically renewed for a further five years — unless the manufacturer falls into a defined non-auto-renewal category or an exclusion scenario applies. The non-auto-renewal list is itself part of the dynamic management framework, so it should be re-checked periodically.
  • More flexible labelling of the registration number. The rigid requirement to display the GACC-assigned number is replaced by a more flexible rule: packaging may carry either the Chinese registration number or the registration number approved by the competent authority in the country of origin.

New Customs Declaration Requirements

From June 1, 2026, food imported into China for human consumption or as a food-processing ingredient must include additional information in the customs declaration that was not previously mandatory. Mismatches between the manufacturer's registration details and the declaration are a common cause of held shipments, so the registration record, the commercial documents, and the declaration all need to align before goods reach the border.

The Transition Window Is Closing

The period from October 14, 2025 to May 31, 2026 is the transition window for enterprises to align existing registrations, update their information, and prepare new applications. From June 1, 2026, GACC applies the new framework to all registrations, changes, and renewals. Applications submitted through CIFER are typically processed in about 20 working days, so leaving registration to the last week before enforcement risks a gap in market access.

With more than 93,000 overseas food manufacturers from 178 countries already registered under the previous regime, the volume of records being migrated and re-verified is substantial — another reason not to wait.

How Zhongshen Can Help

For clients importing food into China, our customs team can confirm whether your products fall under the official-recommendation requirement or qualify for direct self-registration, prepare and submit CIFER applications, identify cold-storage facilities that newly require registration, and align your customs declarations with the updated rules. Contact our customs desk for a pre-June 1 registration review so your shipments keep clearing without interruption.