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New Chinese requirements for imported infant formula products

Trade Advice

On Friday, 6 December, the Ministry for Primary Industries issued formal advice to registered dairy exporters and dairy risk management programme operators about new Chinese requirements for imported infant formula products. This is available on the MPI Foodsafety website: here and here (NB. this second link is password protected. If you do not have a password, instructions for obtaining one are available on the website).

The key points from this formal advice are:

Infant formula manufacturers are required to be registered with Chinese authorities by 1 May 2014;

A registration questionnaire has been published by the Certification and Accreditation Administration of the People’s Republic of China (CNCA). The questionnaire is available on the CNCA website here.

Infant formula manufacturers should commence filling in the form, and work with their verifier to provide it to MPI by 20 December 2013 (no later than 16 January 2014). We strongly recommend providing the completed forms as early as possible. The forms ask manufacturers to list the brands of infant formula they make. Brand owners and exporters should work with their manufacturers to ensure their brand information is accurately reflected in the forms. Brand owners and exporters that do not operate manufacturing premises do not need to fill out separate forms;

Chinese authorities will be visiting New Zealand in February/March 2014 to audit infant formula manufacturing premises;

Effective immediately, infant formula products exported to China must be in consumer ready packaging prior (i.e. packaging of imported bulk ‘finished’ product in-market is no longer permitted). This does not apply to exports of bulk ingredients used in infant formula manufacturing (including bulk infant formula ‘base’ powder intended for further mixing with other ingredients);

Effective immediately, infant formula products exported to China must have at least three months shelf life when they are presented for border clearance in China; and

From 1 April 2014, infant formula products exported to China must be labelled for the Chinese market prior to export (i.e. “over-stickering” in market will no longer be permitted).

The Chinese Government is revising many of its food safety laws, including for infant formula. Exporters are strongly encouraged to monitor regulatory developments in China in order to inform their business planning.

Enquiries should be directed to