On September 25th 2017, China notified the WTO of an addendum^[1] to Notification G/TBT/N/CHN/1209^[2] providing a transition period of two years to implement the controversial certification requirement for foods exported to China, which is set forth in the proposed Administrative Measures on General Certification of Imported Food (hereinafter "Administrative Measures").

The notification states that "according to the comments and application received, China decided to provide a transitional period of 2 years for the Measures, namely from October 1st 2017 to September 30th 2019." 

China has been thinking of implementing a certification system for imported food since 2016. After consulting with stakeholders, a draft regulation was officially notified to the WTO on June 19, 2017, which mandates that foods exported to China be accompanied by an official certificate issued by a competent authority in the exporting country to confirm that the food is manufactured under proper government supervision and is suitable for human consumption. Failure to submit such a certificate will result in a rejection at the port of entry in China. 

As we reported in the latest CRM regarding the draft Implementing Regulations of the Food Safety Law, one of the key concerns on the proposed certification is that it applies to every imported food without distinction based on associated food safety risks. Notably, certain high risk foods, such as seafood and dairy products, are already subject to certain types of certification requirements in China. We understand industry has made suggestions to China to modify the requirement, such as granting exemption to low risk food and seeking clarification on the content of such certificate. 

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_{[1] Click here.}

_{[2] Click here.}