The General Administration of Customs of China (GACC) announced the finalized “Catalogue of Foods that Require Official Recommendation Registration Letters” last week.
Health foods, including health supplements, which were previously not included in the Catalogue during the GACC’s public consultation, were included in the finalized Catalogue.
However, others, such as unroasted coffee beans and cocoa beans, which were omitted from the Catalogue during the public consultation phase, remained excluded.
The Catalogue was published as part of the Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food, also known as Decree No. 280.
Decree No. 280 is also a replacement of Decree No. 248, effective from June 1, 2026. Decree No. 248 was first introduced in 2021.
With the removal of unroasted coffee beans and cocoa beans, Decree No. 280 contains 17 food categories in the Catalogue, one fewer category than Decree No. 248.
Concerns around fake imports?
Commenting on why health foods remained in the Catalogue, Zhang Zhong Peng, secretary-general of China Nutrition and Health Food Association (CNHFA), told NutraIngredients that the Chinese authorities could have been responding to concerns about fake imports.
“The public consultation draft on the Catalogue was published in 2025. During this time, there has been negative news about health foods entering China via cross-border trade or other routes, such as fake cross-border products. As such, keeping health foods in the Catalogue is a sign of maintaining a strict regulatory approach,” he said.
He added that the factory registration should be much more manageable than that of health food product registration - a process required for products sold within China or on local e-commerce platforms, so long as the active ingredients are not listed in the Health Food Raw Materials Directory.
“Decree No. 280 is mainly concerned with the registration of manufacturing facilities that export food products into China via the general trade route,” said Zhang. “For companies producing health foods and food items listed in the Catalogue, they will mainly have to submit recommendation letters from their local competent authorities to prove that their overseas manufacturing facilities exist. This process is easier when compared to the process of registering health foods with the Chinese authorities.”
Cathy Yu, general manager of the food business division at Hangzhou-based regulatory consultancy, also said that the decision to keep health foods in the final Catalogue showed the authority’s strict stance towards special food products.
“Unroasted coffee beans and cocoa beans are primarily classified as primary agricultural products, mainly under the jurisdiction of the Department of Animal and Plant Quarantine, GACC. We believe this change may simply be a further division of customs responsibilities,” she said in a written response. “However, while the draft for comments did state that special dietary foods and health foods did not require registration recommendations, this was retained in the final version, indicating that the Chinese customs maintain a strict approach to the supervision of special foods.”
Reports on fake health foods imports
There are instances where health foods claiming to be made overseas were, in fact, made locally in China.
Local Chinese media CCTV reported on April 28 last year that these fake imports have made claims such as “American brand,” or “imported from the US,” or “100% directly sourced from overseas.”
However, internet search engines outside of China yielded no results on this particular US supplement brand.
Reporters later tracked down a Jiangsu-based company that manufactures health products locally in China, exports them overseas, and imports them back again for domestic sale.
According to the report, such products are sold at about five to 10 times higher than the cost price.
Overseas health foods brands, in particular, those from the US, Germany and Australia are highly preferred by Chinese consumers, with the US topping the list last year.
CBEC products not in the Catalogue
On the other hand, cross-border e-commerce (CBEC) products are not explicitly listed as requiring overseas factory registration in Decree No. 280.
“The management requirements for overseas production enterprises of imported food through CBEC retail shall be handled in accordance with relevant regulations,” said Decree No. 280.
CIRS, in its analysis of Decree No. 280, wrote that products that enter China via CBEC are not regulated as goods but as personal items for inbound use.
Hence, it is of the view that factory registration is not necessary for overseas firms producing health foods sold into China via CBEC.
Still, Zhang believes that the majority of companies, even those that manufacture products for CBEC retail, would already have registered their overseas factories with the GACC.
This is because contract manufacturing of health foods is prevalent in overseas markets and contract manufacturers, which usually produce an array of products, would already have registered their factories with the GACC.
“Based on my conversations with people from the industry, I notice that contract manufacturing is prevalent overseas. These manufacturers may be producing for both CBEC retail and general trade, or are manufacturing health foods and general foods. As such, I believe most overseas factories, including those that produce for CBEC retail, would already have registered themselves when Decree No. 248 was first implemented,” he said.
Catalogue subject to changes
While the Catalogue currently contains 17 food categories, it is subject to changes and could be reduced or expanded, which Zhang said would be a better approach.
“In the past, the food categories listed in the Catalogue were fixed. Now, there is room for adjustment, which I believe is a science-backed and risk-based approach,” said Zhang.
Overseas factories that are successfully registered with the GACC will enjoy a validity period of five years, which will be automatically extended for another five years, except for factories producing meat-based products and edible bird’s nest. These factories will have to be re-registered.
