China's New Manufacturer Registration Rules: What Changes in June 2026

On October 14, 2025, China's General Administration of Customs issued Order No. 280, overhauling registration requirements for overseas food manufacturers. The regulation takes effect June 1, 2026, giving exporters eight months to prepare for substantive procedural changes.

Risk-Based Classification Takes Center Stage

The biggest shift is formalized risk classification. GAC will categorize manufacturers based on their country's food safety system, historical contamination data, and product risk profiles. Higher-risk foods now require official recommendations from the exporting country's competent authority, complete with audit reports. Lower-risk products follow simpler procedures. GAC reserves the right to reclassify products and adjust requirements when evidence suggests changing risks.

The Change That Requires Reapplication

Production site relocations, legal representative changes, or modifications to home country registration numbers aren't treated as simple updates. Article 20 classifies these as fundamental alterations requiring complete reapplication. The existing registration number becomes invalid immediately. What looks like a routine change request becomes a months-long reregistration process.

Automatic Renewal Gets Conditional

Five-year registrations mostly renew automatically, with one critical exception: GAC will publish a list of foods requiring proactive renewal applications submitted three to twelve months before expiration. Miss that window and registration gets cancelled. No grace period exists.

Bilateral Accountability

Order No. 280 places explicit obligations on exporting countries' competent authorities to maintain oversight, suspend exports when problems emerge, and supervise corrective actions. Market access reinstatement depends on home country authorities issuing formal supervision reports, not just internal fixes. This adds a diplomatic layer to what was previously a manufacturer-GAC relationship.

The Transition Window

The eight months until June 2026 should be used to verify whether products will require official recommendations under new risk classifications, assess if bilateral agreements qualify for streamlined list registration, and audit whether recent operational changes might trigger reapplication requirements rather than simple modifications.

For manufacturers exporting to China, Order No. 280 transforms registration from an administrative hurdle into an ongoing compliance commitment requiring coordination with both GAC and home country authorities.

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