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Fish

China (CN)

Considerations prior to updating of establishment details (added 3 June 2021)

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1. Preconditions for market access

1.1 Establishment listing

Initial listing procedure for edible productsRequired?
Export registrationYes
Establishment listing — processed fish productsYes*
Establishment listing — live fishYes**
Chinese listing for exportersYes***

*Establishment listing with China — Processed fish products (non-viable, not live)

The Food Safety Bureau (FSB) of the General Administration of Customs, Peoples Republic of China (GACC) maintains a list of registered seafood establishments approved to export non-viable seafood products to China. The list of approved establishments is available at: GACC Australian approved establishment list.

Prior to export, establishments are advised to confirm their establishment details that appear on export certification for their consignments match the establishment details on GACC's published list. Exporting product on certification that does not match the published list could result in detainment of consignments.

The Department submits a list of establishments who are export registered to manufacture seafood products. The lists are submitted on a quarterly basis in March, June, September and December for China to review and publish the approved establishments on their website.

The Department cannot confirm the timeframe for GACC to update the completed list following our quarterly submissions. The Department utilises every opportunity to progress Australia's applications and listings requests, though the timing of listing is generally outside of the Department's control.

Seafood products exempt from the non-viable eligible species list

The Department has been advised that the (non-viable) eligible species list is not applicable to products whose Harmonised System (HS) tariff codes are located in 1603000090-1605909090 or 2103909000:

  1. 1603 — Extracts and juices of meat, fish or crustaceans, molluscs or other aquatic invertebrates
  2. 1604 — Prepared or preserved fish (whole or in pieces, but not minced) and caviar and caviar substitutes prepared from fish eggs
  3. 1605 — Crustaceans, molluscs and other aquatic invertebrates, prepared or preserved
  4. 21039090 — Sauces and preparations therefor, containing more than 20% by weight, fish crustaceans, molluscs or other aquatic invertebrates.

Industry can investigate whether their seafood products may be legitimately tariffed under the above Harmonised System Codes and therefore exported to China without the need for non-viable eligible species listing. If you are unsure of the Tariff code being applied to your product you should contact your importer or customs broker for further information.

**Establishment listing with China — Live fish

The Animal and Plant Quarantine Division (APQ) of GACC requires a list of registered seafood establishments approved to export live seafood products to China.

In August 2019 the Department provided APQ with an updated list of live establishments. APQ has acknowledged receipt of the list but has not yet advised if the list meets their requirements or if the list will be made publicly available. We will continue to follow up and provide industry with updated information as it becomes available.

Export establishments that have not previously exported live seafood products to China should:

  • note that exports will be at their commercial risk until the Department is able to confirm that APQ has accepted our listing submission
  • work closely with their importers and consider sending small shipments initially to confirm their approval to export and successful clearance of consignments
  • notify the Department immediately should they experience difficulties with clearance of consignments

Live seafood species exported to China must also be eligible under China's live eligible species list for Australia.

***Listing for exporters

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.

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

1.2 Access for products for human consumption

ProductAccess?
*Exporters are encouraged to verify import eligibility of their specific product with their importers prior to export.
FinfishYes*
BivalvesYes*
CrustaceansYes*
EchinodermsYes*
GastropodsYes*
CephalopodsYes*
TunicatesYes*
CrocodileYes*

China has published a list of aquatic species which are eligible for export from Australia to China. This list applies to non-viable seafood. (Note: See 'Oceania' tab. List is best viewed in Google Chrome which provides an option to translate the webpage.)

See the list of live eligible species — download the excel spreadsheet and look for row labelled '澳大利亚'.

1.3 Access for non-prescribed goods

ProductAccess?
Technical products pharmaceutical materialNo agreed certification
Rendered productsNo agreed certification
Crocodile skins and hidesNo agreed certification
ShellsNo agreed certification

Non-prescribed goods are not regulated by the Export Control (Fish and Fish Products) Rules 2021.

Furthermore, the Rules do not apply to:

  • liquid fish products exported in a consignment of no more than 10 litres
  • dried fish and dried fish products (other than dried abalone) exported in a consignment of no more than 2 kilograms
  • fish and fish products (other than liquid fish and dried abalone) exported in a consignment of no more than 10 kilograms.
However, the Department may provide an export certificate if one is required by the importing country competent authority.

1.5 Premises and equipment

China has no known additional requirements for premises and equipment that differ from those required in the Export Control (Fish and Fish Products) Rules 2021.

2. Operational requirements

2.1 General operational requirements

China has no known additional requirements for specific operations that differ from those required in the Export Control (Fish and Fish Products) Rules 2021.

2.2 Microbial and residue sampling, and maximum acceptable limits

Abalone

Chinese import and export inspection and quarantine agencies have enhanced their monitoring of paralytic shellfish toxin (PST) in abalone. The Chinese have a regulatory level for PST of 800µg/kg in all aquatic products.

Maximum acceptable limits for contaminants in fisheries products

Exporters need to ensure that all fisheries products intended for export to China are compliant with all maximum contaminant limits as specified under China's National Food Safety Standard, Maximum Levels of Contaminants in Food – GB 2762–2017. Exporters should also be aware that Chinese customs authorities may sample and test product to verify compliance.

To assist exporters, the below table/extract from GB 2762–2017 has been provided for some metals due to current focus by China on metals in seafood.

A full translation of the GB 2762–2017 standard (PDF 250 KB) has also been provided.

MetalMaximum level
(calculated as Cd) mg/kg
Cadmium
Fish0.1 mg/kg
Crustaceans0.5 mg/kg
Bivalves, gastropods, cephalopods, echinoderms2.0 mg/kg (eviscerated)
Canned fish (excluding canned anchovies, sailfish) 0.2 mg/kg
Canned anchovies, sailfish0.3 mg/kg
Other fish products (excluding anchovy and sailfish products)0.1 mg/kg
Anchovy and sailfish products 0.3 mg/kg
Methyl mercury
Aquatic animals and their products (excluding carnivorous fishes and their products)0.5 mg/kg
Carnivorous fishes and their products1.0 mg/kg
Inorganic arsenic
Aquatic animals and their products (excluding fishers and their products)0.5 mg/kg
Fish and fish products0.1 mg/kg

China has no known additional requirements for microbial sampling of fish and fish products that differ from those required in the Export Control (Fish and Fish Products) Rules 2021.

3. Harvesting and processing

3.1 Sourcing of fish and fish products

China has no known additional requirements for sourcing of fish and fish products that differ from those required by the Export Control (Fish and Fish Products) Rules 2021.

3.2 Sourcing, slaughter and post-mortem inspection of crocodiles

China has no agreed requirements for the slaughter and post-mortem inspection of crocodiles.

3.3 Refrigeration, transfer and loadout

China has no known additional requirements for refrigeration, transfer and loadout that differ from those required by the Export Control (Fish and Fish Products) Rules 2021.

4. Production for human consumption

4.1 Fish and fish products

China has no known additional requirements for the production of fish and fish products that differ from those required by the Export Control (Fish and Fish Products) Rules 2021.

5. Production of non-prescribed goods

5.1 Non-prescribed goods

Technical products and pharmaceutical material

No agreed certification. Please contact import officials to confirm importing country requirements.

Rendered products

Rendered products are non-prescribed goods and are not regulated by the Export Control (Fish and Fish Products) Rules 2021.

Shells

Shells are non-prescribed goods and are not regulated by the Export Control (Fish and Fish Products) Rules 2021.

Crocodile skins and hides

Crocodile skins and hides are non-prescribed goods and are not regulated by the Export Control (Fish and Fish Products) Rules 2021.

6. Labelling, use-by date, trade description and shipping marks (port marks)

6.1 Labelling and trade description

China require outer carton labelling to be in English and Chinese, and should list;

  • product name
  • specifications
  • country of origin
  • production date
  • shelf life
  • storage temperature
  • establishment registration number
  • destination
  • the name and address of the Chinese distributor

The above requirements are in addition to the requirements provided in the Export Control (Fish and Fish Products) Rules 2021.

6.2 Use-by date and or shelf life restrictions

China has no known specific requirements for use-by dates and/or shelf life restrictions in addition to Departmental-administered legislation.

6.3 Shipping marks (port marks)

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

7. Documentation requirements for products for human consumption

7.1 Live seafood

Live finfish, bivalves, crustaceans, echinoderms, gastropods, cephalopods and tunicates

For live aquaculture seafood, use FX46CA certificate.

For live wild caught seafood, use FX46C certificate.

The FX46CA certificate contains the following attestations;

This is to certify that:

  1. The above fishery products come from an establishment approved by the competent authority
  2. The products were produced, packed, stored and transported under sanitary conditions, under the supervision of the competent authority
  3. In accordance with the inspection system regulated by the competent authority, the products were not found to contain pathogenic bacteria, harmful or foreign substances or chemicals
  4. Australia maintains a system that meets OIE requirements for the notification of diseases and epidemiological information in aquatic animals. In respect of farmed aquatic animals, these were examined prior to harvesting for processing or transport and found to be healthy
  5. To the best of my knowledge, the products meet veterinary sanitary requirements and are fit for human consumption

The FX46C Certificate contains the following attestations;

Attestations

This is to certify that:

  1. The above fishery products come from an establishment approved by the competent authority
  2. The products were produced, packed, stored and transported under sanitary conditions, under the supervision of the competent authority
  3. In accordance with the inspection system regulated by the competent authority, the products were not found to contain pathogenic bacteria, or harmful or foreign substances
  4. Australia maintains a system that meets OIE requirements for the notification of diseases and epidemiological information in aquatic animals. In respect of farmed aquatic animals, these were examined prior to harvesting for processing or transport and found to be healthy
  5. To the best of my knowledge, the products meet veterinary sanitary requirements and are fit for human consumption

The Chinese Government requires fishing zones to be included on the health certificates.

7.2 Non-viable seafood

For non-viable seafood products eligible for export to China, use FX46CN certificate.

For non-viable aquaculture origin product, consignments must be accompanied by certification which provides a full list of the aquaculture areas/farm of origin of the products. If products originate from multiple sources, the details of the first three aquaculture areas/farms will appear on the certificate with information on other source establishments automatically printed on an overflow certificate titled 'Aquaculture seafood exported from Australia to the People's Republic of China'.

For non-viable wild caught product, consignments must be accompanied by certification which provides a full list of the names and numbers of the harvest vessels of the products. If products originate from multiple vessels, the details of the first five vessels will appear on the certificate with information on other vessels automatically printed on an overflow certificate titled 'Wild caught seafood exported from Australia to the People's Republic of China'.

The following certification rules for Australian seafood (excluding live) exported to China are required in order to align with Chinese requirements:

Multiple product lines

The format of the FX46CN certificate does not allow for printing of multiple product lines. As a result, each product line on a request for permit (RFP) will generate a separate certificate and incur the standard certificate charge per document issued. For example, if there are three product lines on the RFP, exporters will be issued and charged for three separate government certificates. Previously, only one government certificate would have been generated and charged.

Mixed consignments

The format of the FX46CN certificate does not allow for a single product description/single line entry for mixed consignments, i.e. where different types of products are packed in the same box, such as in trade samples. As a result, the Department is unable to certify products which have more than one type of product in a single box. For example, if one box contains 2 kilograms of lobster and 3 kilograms of prawns, export certification cannot be issued for these products. In order to export these products, the lobsters and prawns would have to be packed in separate boxes, each requiring a separate government certificate.

Processing type

Exporters must ensure that the treatment type field includes one of the following descriptors for the consignment:

  • Refrigerated (CH)
  • Frozen (FR)
  • Dried (DR)
  • Smoked (SM)
  • Canned (CA)

The FX46CN Certificate contains the following attestations;

Attestations

This is to certify that:

  1. The above fishery products come from an establishment approved by the competent authority
  2. The products were produced, packed, stored and transported under sanitary conditions, under the supervision of the competent authority
  3. In accordance with the inspection system regulated by the competent authority, the products were not found to contain pathogenic bacteria, harmful or foreign substances or chemicals inspected and quarantined by competent authority and not found any pathogenic bacteria, harmful substances and foreign substances regulated in the People's Republic of China
  4. To the best of my knowledge, the products meet veterinary sanitary requirements and are fit for human consumption

 The Chinese Government requires fishing zones to be included on the health certificates.

7.3 Crocodiles

There is no agreed certification for crocodile meat into China.

8. Documentation requirements for non-prescribed goods

8.1 Technical products and pharmaceutical material

There is no agreed certification for import of technical products and pharmaceutical materials into China. The Department may not be able to intervene in the event of a detained consignment.

Exporters should check import requirements with their importer or Chinese competent authority prior to shipping any technical products or pharmaceutical material.

Advice received from AQSIQ on 11 April 2017 is that Fish oil tablets do not require health certification.

8.2 Rendered products

There is no agreed certification for import of rendered products into China. The Department may not be able to intervene in the event of a detained consignment.

Exporters should check import requirements with their importer or the importing country competent authority prior to shipping any rendered products.

8.3 Crocodile skins and hides

There is no agreed certification for import of crocodile skins and hides into China. The Department may not be able to intervene in the event of a detained consignment.

Exporters should check import requirements with their importer or the importing country competent authority prior to shipping any crocodile skins and hides.

8.4 Shells

There is no agreed certification for import of shells into China. The Department may not be able to intervene in the event of a detained consignment.

Exporters should check import requirements with their importer or the importing country competent authority prior to shipping any shells.

9. Shipping and air freight requirements

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

10. Port-of-entry clearance inspection and testing

China may conduct port-of-entry checks. Exporters should check with their importer or agent.

11. Definitions

Definitions can be found in the Export Control Act in conjunction with the Australian standard for fish names and the Export Control (Fish and Fish Products) Rules 2021.

Latest updates

15/06/2021 - References to export legislation have been updated.
Last updated: 30/08/2021 4:57 PMCreated: 15/01/2015 12:15 PM