China Proposes Amendments to Imported Pet Food Regulation
On November 15, 2024, China’s General Administration of Customs (GAC) unveiled the amended Measures for the Supervision and Administration of Inspection and Quarantine for Imported and Exported Feed and Feed Additives (hereinafter “draft Measures”) for public comments [1]. In China, pet foods fall within the definition of feed products and, thus, are subject to GAC’s safety supervision and management during import clearance. The proposed regulation builds on the basic regulatory framework for imported pet foods safety supervision and management, covering key areas such as import inspection and quarantine, overseas manufacturer registration, as well as legal responsibilities for violations of the requirements under the draft. Compared with the current effective Management Measures governing imported pet food products [2], the revised version is adjusted from the original 70 articles to 76 articles, with 54 articles revised, 14 added, and 8 deleted.
The draft newly clarifies that imported pet foods are subject to sampling and testing in accordance with the requirements of national biological safety monitoring and safety risk management. It also adds provisions to the measures that GAC may take action against overseas registered manufacturers if their products fail import inspection and quarantine, such as tightening inspection and quarantine, ordering rectification, suspending the import of related products, and revoking relevant registration. Overall, the new proposal represents the authority’s effort to enhance oversight of imported and exported pet foods, built upon years of experience in inspecting and quarantining these products [3].
China has developed extensive regulatory requirements for pet foods. The Chinese Ministry of Agriculture and Rural Affairs (MARA), as the primary governing authority, introduced a series of stringent regulations for pet foods marketed in China, covering product registration, composition, and specification to labeling and claims, etc. For example, overseas manufacturers of compound pet feed and pet additive premix feed must obtain an import registration license from MARA before they can export pet foods to China. In addition, all ingredients and additives used in the manufacture of pet foods must have suitable regulatory status under the positive lists issued by the authority. The Labeling Regulations for Pet Feed serve as the cornerstone of pet food labeling documents, detailing specific requirements for mandatory labeling items (e.g., product name, net weight, use instructions), as well as product claims.
It is worth mentioning that some companies choose to sell pet foods in China via online cross-border e-commerce (CBEC) platforms in parallel to traditional trade routes. If you are interested in further details on CBEC or exporting pet food to China, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), Sharon Tian (tian@khlaw.com), or your existing contact at Keller and Heckman LLP.
[1] http://www.customs.gov.cn/customs/302452/302329/zjz/6207512/index.html
[2] https://www.gov.cn/gongbao/2023/issue_10486/202305/content_6883546.html
[3] See GAC’s accompanying explanatory document, available at: http://www.customs.gov.cn/customs/302452/302329/zjz/6207512/2024111513271610729.docx