Decree 248 Registration: Part 1

Описание: A basic introduction to cifer.singlewindow.cn and setting up a new GACC account.

BACKGROUND
Decree 248 went into effect on Jan 1, 2022. All food processing facilities and warehouses involved in exporting to China must register with GACC (China’s General Administration of Customs – Formerly CIQ). All food products that are exported from these facilities must be included under the facility’s GACC CIFER account/s.

Decree 248 set up different categories of food products based on China’s perceived risk levels throwing lower-risk products like raw nuts and seeds in with meat, dairy and seafood under its Article 7 group of commodities that require registration support from the foreign country’s competent authorities. FDA is competent authority for raw nuts and seeds. All other commodities fall under Article 9 and can be self-registered using China’s cifer.singlewindow.cn portal.

Before US companies can register with China, it is important that they use their FDA Establishment Identifier number (FEI) as their US registration number (for nuts and seeds). For Article 7 products, companies must first register using the FDA’s Export Listing Module (ELM) which is required to authenticate the facility’s new GACC CIFER accounts before they can start uploading mandatory information required to register.

It is important to note that facilities with one FEI number may end up with multiple GACC approval numbers which are based on the GACC commodity categories – eg: raw nuts are under category 12, while edible oils are under category 6 (both Art 7) and processed nuts are under category 22 (Art 9).

US facilities should keep a computer folder with basic documents that will be needed to complete their GACC registrations including PDF copies of their business license, certain HACCP documents, processing flow charts for each commodity, copy of their signed/stamped enterprise statement, records of previous exports to China in metric tons, total processing capacities in metric tons, information on pesticide use (fumigants), affiliate/toll processing partners, and signed copy of GACC’s self-assessment checklists. GACC approval numbers need to be included on the labels of the products being exported to China. Therefore, each firm needs to keep track of these GACC accounts/PWs, etc.