China: Status Update on Facilities Registration and Food Safety Measures

China’s trading partners and industry members have concerns about potential disruptions from two revised decrees that China announced in April 2021, the Regulations on the Registration and Administration of Overseas Producers of Imported Food (Degree 248) and the Administrative Measures on Import and Export Food Safety (Degree 249). Both decrees are slated to enter into force in less than 8 months, and sources conveyed this was an insufficient time for industry and foreign competent authorities to comply with the requirements. Chinese importers are unaware of how to comply, too. Furthermore, there is an almost complete lack of clarity about how the decrees will be implemented and the implications for trade, including additional risks, costs, and administrative burdens for all parties. To date, China has provided limited feedback to trading partners’ comments on both decrees, while promising to publish implementing rules on Decree 248 as early as June 2021.