Registration deadline for China's new food and beverage rule looms. (pic: iStock)
China Wine

Here’s all you need to know about China’s new wine import rules

Heading into 2022, wineries, wine producers and exporters might find their access to the lucrative Chinese market at risk, as China’s new customs regulations on food and beverage entry has sent producers and exporters scrambling to fill out registration before the looming January 1 deadline. 

Heading into 2022, wineries, wine producers and exporters might find their access to the lucrative Chinese market at risk, as China’s new customs regulations on food and beverage entry has sent producers and exporters scrambling to fill out registration before the looming January 1 deadline. 

Earlier in April this year, China issued two decrees — 248 and 249 — that set out the new requirements. The two main requirements request all foreign food manufacturing, processing and storage facilities to be registered with the General Administration of Customs of the People’s Republic of China (GACC), and include their registration codes on product labelings.

China changed its import rules on wine and spirits (pic: iStock)
China changed its import rules on wine and spirits (pic: iStock)

However, the detailed procedures to get the required registration codes only came out in October, and the registration website for companies who are eligible to self-register started operating just last month.

The tight deadlines and strict registration process without much clear explanation in foreign languages have fuelled anxiety and confusion of wineries, exporters, and even diplomats and international trade groups, with many complaining about lack of guidance, clarity and a move that’s perceived as potentially shunning imported wines over Chinese wines.

Here are some key points we have summarized regarding the new rules to guide you through the process, if you haven’t already registered.

What are the new changes?

Previously only wine and spirits importers were required to fill out wine information about imported wine, but the new rule announced in April this year would require all wineries and any facilities involved in manufacturing, processing and storage facilities to  fill out a detailed registration form online, which includes questions on manufacturing location, operation modes and even water supply. 

What does this mean for wines and spirits?

According to the guideline issued by Wine Australia, for the registration process, wine production and storage facilities handling wine exports to China must be registered with GACC before the product is cleared in China. This may include the facility at which packaging or bottling occurred, or the sites where the product was transferred to the bulk tanks or vessels in which it is exported.

For the labelling process, wine and wine products ready for export, no matter packaged, bottled or loaded into bulk containers, are required to bear the registration number starting from 1 January 2022. 

The registration number is also required to be included in the customs clearance documentation for products shipped from 1 January 2022. For this case, exporters can liaise with their importers to ensure this step is completed.

Operators without completing the above registration and labelling processes will have their goods blocked at customs upon entry into China.

Why is it important? 

If you are exporting wines to China and fail to fill out the form in time, you will lose your access to the vast Chinese market, and your products won’t be able to be sold in the Chinese market. 

Why is it causing panic?

The rules were introduced in April, but the registration website in English was only launched in November, leaving little time for producers and wineries to fill out the form. This means wine arrivals for China’s biggest Lunar New Year Festival will be greatly affected. 

The problem is compounded when the global supply chain is already strained because of shortage of containers and hiked prices, causing shipments delay. The added omicron surge across the globe is also expected to slow down future shipment if ports are disrupted.  

Registration deadline for China's new food and beverage rule looms. (pic: iStock)
Registration deadline for China’s new food and beverage rule looms. (pic: iStock)

When are they effective?

Although the effective date to enforce the new rule is set to be January 1, 2022, GACC has agreed that the implementation should only apply to goods produced on or after Jan 1, after diplomats and trade groups complained about lack of time, as reported by Reuters

In the case of wines and spirits, this means products bottled on or after January 1, 2022. It should be noted however that the extension agreement has not been officially announced. 

Given that the timeline for GACC’s registration approval and insurance of the registration number is unclear, applicants are advised to register as soon as possible.

How to apply?

According to a guideline issued by the Fédération des Exportateurs de Vins & Spiritueux de France, the goods ready for export into China are disguised into two categories — high-risk and low-risk. 

Wines and spirits are considered low-risk products that can go through a simpler “self-registration” process via China’s International Trade Single Window System. The registration will need to be approved by the GACC before it becomes valid.

The China Import Food Enterprises Registration platform for self-registration is currently available in English. However, it is reflected that the English version is in trial, which may extend the registration process due to language inconvenience.  

After creating a user account, applicants need to submit a registration form asking for information including name and address of the company, name of the legal representative, telephone number, fax number, registration number approved by the authority responsible for the country where the establishment is located etc. Applicants also need to submit a company identification document and a letter to comply with Chinese regulatory requirements.

What should we be aware of during the registration process?

The registration request cannot be modified after submission, especially if the operator wants to add products afterwards, so applicants are advised to check all the exporting products before submitting the request. 

After the request is approved by the GACC, a registration number would be issued to the operator. Operators need to renew the registration every 5 years, which must be requested three to six months before the expiration of the previous registration.

It is worth mentioning that the whole process is free of charge, so operators need to be aware of any related scams or similar platforms that require a large sum of registration fees. Applicants are also strongly recommended not to assign the registration process to a third party such as importer or commercial agents.

How long will it take to get approved? 

Here’s the tricky part. It is not specified and wineries who talked to us said the time varies from weeks to more than a month. After initial registration with all the information about the winery, manufacturing plant and the wine information, normally Chinese customs will reach out for corrections and additional information if not filled correctly. 

Again, it’s worthy to note that once information is uploaded, you can’t modify the form online.

Additional reporting from Ning Sang Lawati

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