All Australian dairy manufacturing establishments exporting prescribed dairy goods for human consumption to China need to register through the China Import Food Enterprise Registration (CIFER) system and be approved by the General Administration of Customs of China (GACC). Please contact the Department at dairyeggsfish@aff.gov.au for further information prior to lodging any application with GACC.​

Decree 248 and 249

Imports of food into China are regulated through Decree 248 Regulations of the People's Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food and 249 Measures of the People's Republic of China for the Administration of Import and Export Food Safety.

A summary of these Decrees may be obtained from the United States Department of Agriculture, Global Agricultural Information Network reports via the following links:

• China: Regulations on the Registration and Administration of Overseas Producers of Imported Food - Decree 248 (PDF 425 KB)
  
• China: Administrative Measures on Import and Export Food Safety - Decree 249 (PDF 473 KB)​

Overseas establishment registration is made through the China Import Food Enterprises Registration (CIFER) system prior to importing food products. Please contact the Department at dairyeggsfish@aff.gov.au for further information prior to lodging any application with GACC.

Listing for exporters

This Chinese Government Listing process is independent of other listing requirements.​

China's General Administration of Quality Supervision, Inspection and Quarantine (now GACC), introduced Decree 55 on 1 October 2012 as part of China's food safety law. Decree 55 requires Australian exporters and agents, as well as Chinese importers, to complete a web-based registration process. Company details must be registered through the Chinese government's e-platform​.

The Department understands the registration process is administrative in nature and is the responsibility of relevant commercial parties. The registration form can be completed via the portal​. When accessing this portal, at the base of the page, there are detailed instruction manuals for exporters and agents, as well as importers, under the section "User Manual". Whilst the manuals contain detailed step-by-step instructions as to how to complete the registration process, it is currently only available in the Chinese language; therefore exporters are encouraged to work closely with their importers to provide the required information.

The Department understands that the portal has the capacity to capture basic information of exporters, agents and importers, including name, address, contact details and the type of food commodity (via a checkbox option). The portal has the capacity to capture multiple importers for each exporter, and does not require the input of consignment specific information. The portal also allows amendments to registered information to accommodate for changes in exporter/agent/importer details, as well as being able to indicate the status of registration applications.​

Australia does not currently have market access for camel milk and camel milk products (this also applies where the product is a blend containing only a small component of camel milk) or extended shelf life (ESL) milk products into China. These products are currently prohibited for export to this market. Refer to section 5.1 for more details.

Milk and milk products of bovine origin are defined as prescribed goods under the Export Control Act 2020. When these products are produced for export they are regulated under the Export Control (Milk and Milk Products) Rules 2021.

Milk and milk products manufactured from non-bovine species, for example buffalo, goat and sheep, may also be regulated through the Export Control (Milk and Milk Products) Rules 2021 when export registration and health certification from the Department is required by an importing country.

Exporters must be aware and ensure they comply with China's requirements for export certification for milk and milk products of non-bovine species and colostrum (refer to section 5.1).

Refer to section 2.2 on compositional requirements for additional information on China's food safety standards.

The following national food safety standards were provided to the Department when they were notified by China to the WTO in 2010. The department recommends exporters should obtain current versions of these standards from their importer. It is the responsibility of exporters to ensure they comply with all of China's importing country reqeuirements for their products.

• Pasteurised milk
  
• Modified milk
  
• Concentrated dairy products (see section 2.2.2)
  
• Processed cheese and cheese products (see section 2.2.2)
  
• fermented milk
  
• sterilised milk
  
• milk powder
  
• cream, butter and anhydrous milk fat
  
• cheese
  
• infant formula (see section 2.2.2)
  
• infant formula for special medical conditions 
  
• follow-up formula.
  

Food additives

Chinese requirements for food additives are detailed in the National Standard of the People's Republic of China GB2760-2014 (PDF 2.2 MB), which provides details of the acceptable residue levels.

2.2.2 GACC announcement on standards including infant formula, concentrated dairy products and processed cheese​​

GACC Announcement 136-2022​

On 30 December 2022, the General Administration of Customs China (GACC) released Announcement 136-2022 regarding the implementation of requirements for the inspection of food products for compliance with national food safety standards (hereinafter referred to as the new standards). Food products affected include infant formula, concentrated dairy products and processed cheeses. These standards are listed in the above table and relate to: GB 10765-2021 National Food Safety Standard Infant Formula; GB 10766-2021 National Food Safety Standard Older Infant Formula; GB 10767-2021 National Food Safety Standard Young Children Formula; GB 13102-2022 National Food Safety Standard Concentrated Dairy Products and GB 25192-2022 National Food Safety Standard Processed Cheese and Cheese Products

Below are notable changes in the five standards.

Infant Formula - notable changes between the new standard GB 10765-2021 and the previous standard GB 10765-2010

• Scope: scope of the standard has changed from 0-12 months to 0-6 months.
• Terms and definitions: ‘primary raw materials’ made from milk and milk protein products and soy and soy protein products has been changed to ‘primary protein sources’.
• Nutrients: minimum or maximum values of some nutrients have been revised or added.
• Bean-based infant formula: requirements for the content of iron, zinc and phosphorus in bean-based infant formula have been added.
• Choline: Choline is now an essential component.
• Appendix A: information on essential and semi-essential amino acids has been revised.
• Appendix B: additional information restricting the use of source of monomer amino acid has been added.
• Testing methods: multiple changes in testing have been made.​​​

Older Infant Formula - notable changes in the new GB 10766-2021 compared with the previous GB 10766-1997 and GB 10767-2010

• The scope of the standard has changed from the age of 0 to 36 months (old standard) to 6 to 12 months (new standard).
• Changes to the terms and definitions include a distinction between dairy-based formula and bean-based formula.
• Lactalbumin and lactose requirements have been added.
• Minimum or maximum values of most nutrients have been revised or added.
• Requirements for protein, iron, zinc and phosphorus have been added for bean-based infant formula: It refers to the products manufactured and processed only through physical method by taking soy and soy protein products as the major protein source added with an appropriate amount of vitamins, minerals and/or other raw materials.
• Additional essential components have been added including: manganese, selenium and choline
• Images of babies and women are prohibited on labels.
• Appendixes A and B for amino acids have been added. Appendix recommends values of essential and semi-essential amino acids in older infant formula. Appendix B specifies monomeric amino acids that can be used in older infant formula.
• There are multiple changes in testing methods.​

Young Children Formula - notable changes between the GB 10767-2021 and the previous GB 10767-2010

• The scope of the standard has changed from 6 to 36 months to 12 to 36 months.
• Lactose requirements have been added.
• Minimum or maximum values of some nutrients have been revised or added.
• Multiple changes in testing methods have been made.​

Concentrated Dairy Products - notable changes between the GB 13102-2022 and the previous GB 13102-2010

• The title of the standard has been amended to: National Food Safety Standard for Concentrated Dairy Products.
• There are added physicochemical indicators for:
• partially-skimmed milk
• skimmed condensed milk
• partially-skimmed formulated condensed milk, and
• skimmed formulated condensed milk.
• There are additional temperature requirements.
• Added/revised testing requirements are included for concentrated dairy products, sweetened condensed milk and formulated condensed milk.

Processed Cheese and Cheese Products - notable changes between the new GB 25192-2022 and the previous GB 25192-2010

• The title of the standard has been amended to: National Food Safety Standard for Processed Cheese and Cheese Products.
• New requirements of this standard include:
• Processed cheese must now include cheese at over 50% of total ingredients
• Cheese products may have a cheese content of 15 to 50 percent of the final product.
• The product label must now clearly indicate transportation and storage temperature.
• The standards also include additional and revised testing requirements for processed cheeses and cheese products.
  

Equivalence with China's good manufacturing practice standards

Australia's standards meet the same outcomes as:

• China's Good Manufacturing Standard for milk products (GB12693-2010 (PDF 340 KB) and
• China's Good Manufacturing Standard for powdered formula for infants and young children (GB23790-2010 (PDF 110 KB).

The Department has completed an equivalence table (PDF 1.1 MB) which outlines how these requirements are met though Australia's standards.

Unless technical products and pharmaceutical material are prepared at an establishment that produces milk and milk products for export as food, these products are non prescribed goods. They are not regulated by the Export Control (Milk and Milk Products) Rules 2021.

Unless animal food is prepared at an establishment that produces milk and milk products for export as food, these products are non prescribed goods.

In accordance with the Export Control (Milk and Milk Products) Rules 2021, animal food must be clearly identified as animal food and not for human consumption. It must also be segregated from and not contaminate milk and milk products that are for human consumption.

China has no known additional requirements for Manufacturing Grade milk and milk products that differ from the Export Control (Milk and Milk Products) Rules 2021.

The Department does not have information about China's requirements for manufacturing grade (DM) milk and milk products, animal food and technical products including pharmaceutical material. Exporters are strongly recommended to check with their importer whether these products can be imported into China.

On 6 July 2021, China’s General Administration of Customs (GACC) issued Ann​ouncement No. 50 - 2021 (PDF 393KB) (Announcement on the Implementation of a Notification and Commitment System on Certification Items of the Testing Report for Imported Dairy Products). It allows importers (or agents) to provide a letter of commitment (LOC), instead of the original testing reports, for first-time dairy imports to clear customs. Importers (or agents) may also continue to submit the original testing report for customs clearance.

China residue standards

Maximum residue limits (MRLs) or import tolerances for residues of specific agricultural and veterinary chemicals approved for use in Australia may not exist in China or may be established at levels lower than those established in Australia. Maximum Limits (MLs) for contaminants may also vary between China and Australia.

Food business operators should note that:

• These differences can be interrogated case-by-case by considering the China​ standards and the Australian standards.
• Any detection of a residue above the China MRLs/MLs (as applicable) at the border may result in rejection of the consignment.

Note

Importing country residue standards can usually be found via the official webpages of their competent authority. Links to a limited number of export markets and Australia are provided on the DAFF website.

China has no known additional requirements for general operations that differ to those required in the Export Control (Milk and Milk Products) Rules 2021.

China has no known additional hygiene requirements that differ to those required in the Export Control (Milk and Milk Products) Rules 2021.

Milk and milk products that are prescribed under Australia's export rules

1. are milk or milk products derived from a bovine animal; and
2. are intended to be exported as food.

Milk and milk products that are not prescribed under Australia's export rules

Milk and milk products which do not meet the criteria under the Export Control (Milk and Milk Products) Rules 2021 are classified by Australia as non-prescribed goods. It is the responsibility of the exporter to confirm with China if there are any specific requirements for the import of these products. Typically, non-prescribed goods include ice cream;non-bovine milk products; colostrum and products with a minor component of dairy. 

Further information on exporting non-prescribed goods from Australia is available on the Department's website.

In some cases, an importing country requires specific health certification and government oversight for what would typically be non-prescribed milk and milk products. When required by an importing country, these products become prescribed under export legislation and must meet all export and importing country requirements. This includes that the products being manufactured and stored at an export registered establishment and must have a valid export permit and health certificate for each consignment. Guidance on export registration can be found at Dairy export registered establishments.

Health certification for milk and milk products

For milk and milk products produced for human consumption (including milk and milk products classified as a prescribed good by an importing Country), use either health certificate template ZDCN01 (stage one infant formula) or ZDCN02 (for products other than stage one infant formula).

Exporter declarations

Whenever export documentation is obtained, the exporter must provide a declaration stating that all the information provided in the permit is true and complete. They must also state that they are in possession of a declaration of compliance that:

1. applies to the milk and milk products
2. complies with the requirements of the Export Control (Milk and Milk Products) Rules 2021.

The following exporter declaration is needed for fresh liquid milk (MIL) dairy products:

"The milk in this REX complies with Chinese requirements for heat treatment, cold chain, packaging, shelf life and end product testing and is eligible for entry into China."

The following exporter declaration is needed for infant formula (INF) products:

"The infant formula in this REX complies with Chinese requirements for Cronobacter (Enterobacter) sakazakii and is eligible for entry into China."

Health certification for milk and milk products of non-bovine origin

Health Certificate template ZDCN01 (stage one infant formula) or ZDCN02 (for products other than s​tage one infant formula) are to be used.

For non-bovine milk and milk products and colostrum for human consumption (including milk and milk products of buffalo, goat and sheep species) to China to be eligible for health certification, the manufacturer must be export registered. Guidance on export registration for manufacturer's producing non-bovine milk and milk products can be found at Dairy export registered establishments.​

Note on prohibited products: Exporters should be aware of that Australia does not currently have market access for camel milk and camel milk products or extended shelf life (E​​​SL) milk products into China.

For further information on export registration and exporting non-bovine milk and milk products and colostrum for human consumption to China please contact the Dairy Eggs and Fish Program at dairyeggsfish@agriculture.gov.au.

Stage one infant formula

The ZDCN01 Health Certificate template which contains the following attestations:

• The above product has been tested in Australia and found to be free of Enterobacter sakazakii
• Animals from which these products were taken were free from clinical diseases caused by agents listed in the Office international des Epizooties List A for the species concerned and live in an area free of these diseases. I further certify that Foot and Mouth Disease, Rinderpest and Bovine Spongiform Encephalopathy do not exist in Australia.

  The above dairy products have been prepared from pasteurised milk or milk that has received treatment of equivalent severity.

• I hereby certify that to the best of my knowledge the conditions or restrictions applicable under the particular inspection system prescribed under the Export Control Act have been complied with in respect of the prescribed good described above, being goods that are:
  
  
  1. In sound condition
  2. Fit for human consumption
  3. Of Australian Origin

All stage one infant formula being exported to China must be tested for Cronobacter (Enterobacter) sakazakii, you must have analytical certificates issued by National Association of Testing Authorities (NATA) accredited laboratories which substantiate the certificate endorsement "The above product has been tested in Australia and found to be free of Cronobacter (Enterobacter) sakazakii." These certificates must be available during audit or as requested by the Department.

Please note that Enterobacter sakazakii is the former name for Cronobacter sakazakii.

Milk and milk products other than stage one infant formula

The ZDCN02 Health Certificate template which contains the following attestations:

• The above dairy products have been prepared from pasteurised milk or milk that has received treatment of equivalent severity. Animals from which these products were taken were free from clinical diseases caused by agents listed in the Office international des Epizooties List A for the species concerned and live in an area free of these diseases. I further certify that Foot and Mouth Disease, Rinderpest and Bovine Spongiform Encephalopathy do not exist in Australia.
  
• I hereby certify that to the best of my knowledge the conditions or restrictions applicable under the particular inspection system prescribed under the Export Control Act have been complied with in respect of the prescribed good described above, being goods that are:
  
  
  1. In sound condition
  2. Fit for human consumption
  3. Of Australian origin

Transit certification requirements

Milk and milk products transiting the European Union or the United States may require transit documentation. These certificates are available as additional certificates through the Department's electronic certification system. If the product is transiting the United States, standard certification is required and the exporter should contact the Department for advice on how this certification may be issued. If the product is transiting a European Union member state, see the particular European Union member state regarding the certificate template to select.

The Department does not have information about certification requirements for Manufacturing Grade products exported to China.

Some countries may accept the ZD016 Certificate as to Condition for Manufacturing Grade products. Exporters should check certificate requirements with their importer.

Certificate as to condition for manufacturing grade products

The ZD016 Certificate as to Condition contains the following attestations:

I hereby certify that to the best of my knowledge the conditions or restrictions applicable under the particular inspection system prescribed under the Export Control Act have been complied with in respect of the prescribed good described above, being goods that are:

1. In sound condition
2. Of Australian Origin.
   

The Department does not have information about certification requirements for exports of technical product and pharmaceutical material to China.

Some countries may accept the ZD001 Certificate as to Condition. Exporters should check certificate requirements with their importer.

Certificate as to condition

The ZD001 Certificate contains the following attestations:

I certify to the best of my knowledge that the information on this form is true and correct in every particular details and that the product described above is of Australian origin and is acceptable for sale in Australia.

The Department does not have information about certification requirements for stockfood exported to China.

Some countries may accept the ZD015 Certificate as to Condition for stockfood. Exporters should check certificate requirements with their importer.

Certificate as to condition for stockfood products

The ZD015 Certificate as to Condition for Stockfood or the E242A Declaration and Certificate for Shipments of Inedible Animal Products can be issued for stockfood made from milk and milk products.

The ZD015 Certificate contains the following attestations:

I hereby certify that to the best of my knowledge the conditions or restrictions applicable under the particular inspection system prescribed under the Export Control Act have been complied with in respect of the prescribed good described above, being goods that are:

1. In sound condition
2. Of Australian Origin.
   

The E242A Declaration and Certificate contains the following attestations:

It has been declared to me, a duly qualified veterinary surgeon in the employ of the Government of the Commonwealth of Australia and I have no reason to doubt the products described above were derived from animals of Australian origin and the products were treated solely within Australia. I further certify that foot-and-mouth disease and rinderpest do not exist in Australia.

It is the responsibility of exporters to determine through their importers if export certification is required for consignments and trade samples that are less than 10 kilograms or 10 litres, as an export permit is not required for such consignments.

The Food Safety Bureau of the Chinese competent authorities has requested that exporters and exhibitors intending to send samples to dairy expos make necessary preparations well in advance for their own benefit. Importers are required to notify the Food Safety Bureau of the Chinese competent authorities with product details, variety, specifications and quantity so that inspection and clearance can be made in time for the expositions.

The ZX01 Certificate as to Dioxin Status of Australian Dairy Products is available on request.

European Union (EU) transit certificates are available for consignments transiting the EU. Refer to the EU documentation requirements for edible products for the reference numbers and attestations in these certificates.

Further information​​​​​​​​

The Department does not have information about China's requirements for manufacturing grade (DM) milk and milk products, animal food and technical products including pharmaceutical material. Exporters are strongly recommended to check with their importer whether these products can be imported into China.

Exporters should ensure that their importer complies with any requirements to obtain a permit for imports into China.

​According to Decree 249 - Measures of the People's ​Republic of China for the Administration of Import and Export Food Safety (PDF 353KB) , the packaging and labelling requirements are included but not limited in its Articles 28, 29, 30, 45 and 46.

According to Dec​ree 249 - Measures of the People's Republic of China for the Administration of Import and Export Food Safety (PDF 353KB), the packaging and labelling requirements are included but not limited in Articles 28, 29, 30, 45 and 46 of Decree 249, and Part I (PDF 508KB)​ and Part II (PDF 397KB) of GB 7718-2011, General Rules for the Labelling of prepackaged foods. Link to Decree 249 can be found at section 1.2.​

China has no known specific requirements for shelf life restrictions other than those provided in the Export Control (Milk and Milk Products) Rules 2021.

China has no known specific requirements for shipping marks (port marks).

Nutritional labelling

The United States has completed a report in 2021 on China's draft regulation on nutritional labelling (PDF 697KB)  which may provide guidance on requirements.

Exporters should check current requirements with their importers.

China has no known specific requirements for shipping and airfreight. Milk and milk products must be transported to ensure their condition and integrity is maintained in accordance with the requirements of the Export Control (Milk and Milk Products) Rules 2021.​