To further regulate the management of import and export food trader registration, streamline registration procedures, and ensure the safety of imported food, the General Administration of Customs has drafted the Announcement on the Registration of Import and Export Food Traders (Draft for Comments). This draft was released on January 21, 2025, for public consultation, with feedback due by January 27, 2025.
The Draft for Comments consists of 10 articles aimed at improving the registration system for import and export food traders by simplifying procedures, enhancing efficiency, and optimizing management. It further seeks to strengthen corporate responsibility and elevate the level of administrative services. The main contents of the Draft for Comments are as follows:
1. Simplification of Registration Materials
The Draft for Comments proposes that enterprises registering as food importers only need to complete the Food Importer Registration Information Form, eliminating three registration documents. The number of items required for registration has been reduced from 20 to 16, with enterprises only needing to provide basic information such as the company name, unified social credit code, registered address, contact person, and legal representative. Similarly, the registration requirements for foreign exporters or agents of imported food have been reduced from 20 items to as few as 10, requiring only essential information such as company name, address, country (region), contact person, and contact information.
This initiative reduces the burden on enterprises and improves the business environment. By cutting unnecessary materials, compliance costs for businesses are lowered, while transparency and simplicity in customs registration management are enhanced. However, it is crucial to ensure that the simplified materials still meet regulatory requirements. For instance, while the number of registration items is reduced, the accuracy and completeness of critical data must be ensured through system validation and follow-up supervision.
2. Shortening Registration Timeframes
The Draft for Comments specifies that the customs processing time for registering import and export food traders will be uniformly set at three working days to enhance efficiency and increase the predictability of administrative services.
Shortening registration timeframes is a significant measure to improve administrative efficiency and can substantially enhance the user experience for businesses. In the past, companies may have encountered delays and feedback lags during the registration process, disrupting business operations. The explicit provision of a three-working-day timeframe not only strengthens the government’s commitment to service delivery but also provides businesses with a clearer expectation, enabling smoother operations in the import-export food trade. However, customs authorities must optimize their technological systems and staffing to ensure timely completion of registration, even during peak periods.
3. Streamlining Registration Procedures
The Draft for Comments proposes leveraging the Customs Unified Management Subsystem for Administrative Counterparties (Version 3.0)—a system introduced by the General Administration of Customs in November 2023 to centrally manage and optimize services for administrative counterparties (i.e., businesses and individuals interacting with customs). The system will enable the one-time collection of basic enterprise registration information, avoiding repetitive data entry by businesses. Additionally, enterprises can apply for food importer registration while simultaneously registering as a customs declarant, enabling “one registration for multiple matters.”
This innovative measure reflects customs’ continued progress in digitization and intelligence. System upgrades simplify operations for businesses, eliminating inefficiencies such as duplicate submissions and fragmented processing. The “one registration for multiple matters” feature saves businesses time and labor costs. However, during implementation, it is critical to ensure system stability and data security to prevent disruptions caused by technical failures or data breaches, which could hinder registration or harm business interests.
4. Optimizing Registration Management
In accordance with the Regulations of the People’s Republic of China on the Administration of Food Import and Export Safety, the Draft for Comments further strengthens corporate responsibility by clarifying requirements for timely registration changes. It also stipulates that customs may proactively cancel the registration of food importers in cases where they are deregistered, have their registration revoked, or lose their business licenses due to dissolution, bankruptcy, or other statutory reasons, thereby establishing a more robust exit mechanism.
This provision strengthens corporate responsibility while providing customs with greater flexibility in management. In practice, some enterprises fail to update their registration information or deregister when operations cease, resulting in redundant data within the customs system and complicating oversight. The proactive cancellation and exit mechanism not only enhances data accuracy but also reduces compliance risks for businesses. However, it is recommended that the implementation process further clarify specific procedures for proactive cancellation and provide mechanisms for appeals to avoid unnecessary disputes arising from communication gaps or data inaccuracies.
[Comment]
The Draft for Comments introduces multi-faceted measures, including simplifying registration materials, shortening processing times, streamlining procedures, and optimizing management, to strongly support the legal and standardized development of the import and export food industry.
However, policy improvement is only the first step. Its successful implementation and realization of intended outcomes depend on meticulous management and technical support during execution. Customs may need to simultaneously focus on system development, enterprise training, and subsequent oversight to ensure the smooth progress of reform initiatives. Regular disclosure of reform outcomes and data is encouraged, along with soliciting feedback from various stakeholders to further refine the system. By building a more efficient and transparent food registration management system, the General Administration of Customs can provide higher-quality services to both enterprises and consumers.
The Draft for Comments consists of 10 articles aimed at improving the registration system for import and export food traders by simplifying procedures, enhancing efficiency, and optimizing management. It further seeks to strengthen corporate responsibility and elevate the level of administrative services. The main contents of the Draft for Comments are as follows:
1. Simplification of Registration Materials
The Draft for Comments proposes that enterprises registering as food importers only need to complete the Food Importer Registration Information Form, eliminating three registration documents. The number of items required for registration has been reduced from 20 to 16, with enterprises only needing to provide basic information such as the company name, unified social credit code, registered address, contact person, and legal representative. Similarly, the registration requirements for foreign exporters or agents of imported food have been reduced from 20 items to as few as 10, requiring only essential information such as company name, address, country (region), contact person, and contact information.
This initiative reduces the burden on enterprises and improves the business environment. By cutting unnecessary materials, compliance costs for businesses are lowered, while transparency and simplicity in customs registration management are enhanced. However, it is crucial to ensure that the simplified materials still meet regulatory requirements. For instance, while the number of registration items is reduced, the accuracy and completeness of critical data must be ensured through system validation and follow-up supervision.
2. Shortening Registration Timeframes
The Draft for Comments specifies that the customs processing time for registering import and export food traders will be uniformly set at three working days to enhance efficiency and increase the predictability of administrative services.
Shortening registration timeframes is a significant measure to improve administrative efficiency and can substantially enhance the user experience for businesses. In the past, companies may have encountered delays and feedback lags during the registration process, disrupting business operations. The explicit provision of a three-working-day timeframe not only strengthens the government’s commitment to service delivery but also provides businesses with a clearer expectation, enabling smoother operations in the import-export food trade. However, customs authorities must optimize their technological systems and staffing to ensure timely completion of registration, even during peak periods.
3. Streamlining Registration Procedures
The Draft for Comments proposes leveraging the Customs Unified Management Subsystem for Administrative Counterparties (Version 3.0)—a system introduced by the General Administration of Customs in November 2023 to centrally manage and optimize services for administrative counterparties (i.e., businesses and individuals interacting with customs). The system will enable the one-time collection of basic enterprise registration information, avoiding repetitive data entry by businesses. Additionally, enterprises can apply for food importer registration while simultaneously registering as a customs declarant, enabling “one registration for multiple matters.”
This innovative measure reflects customs’ continued progress in digitization and intelligence. System upgrades simplify operations for businesses, eliminating inefficiencies such as duplicate submissions and fragmented processing. The “one registration for multiple matters” feature saves businesses time and labor costs. However, during implementation, it is critical to ensure system stability and data security to prevent disruptions caused by technical failures or data breaches, which could hinder registration or harm business interests.
4. Optimizing Registration Management
In accordance with the Regulations of the People’s Republic of China on the Administration of Food Import and Export Safety, the Draft for Comments further strengthens corporate responsibility by clarifying requirements for timely registration changes. It also stipulates that customs may proactively cancel the registration of food importers in cases where they are deregistered, have their registration revoked, or lose their business licenses due to dissolution, bankruptcy, or other statutory reasons, thereby establishing a more robust exit mechanism.
This provision strengthens corporate responsibility while providing customs with greater flexibility in management. In practice, some enterprises fail to update their registration information or deregister when operations cease, resulting in redundant data within the customs system and complicating oversight. The proactive cancellation and exit mechanism not only enhances data accuracy but also reduces compliance risks for businesses. However, it is recommended that the implementation process further clarify specific procedures for proactive cancellation and provide mechanisms for appeals to avoid unnecessary disputes arising from communication gaps or data inaccuracies.
[Comment]
The Draft for Comments introduces multi-faceted measures, including simplifying registration materials, shortening processing times, streamlining procedures, and optimizing management, to strongly support the legal and standardized development of the import and export food industry.
However, policy improvement is only the first step. Its successful implementation and realization of intended outcomes depend on meticulous management and technical support during execution. Customs may need to simultaneously focus on system development, enterprise training, and subsequent oversight to ensure the smooth progress of reform initiatives. Regular disclosure of reform outcomes and data is encouraged, along with soliciting feedback from various stakeholders to further refine the system. By building a more efficient and transparent food registration management system, the General Administration of Customs can provide higher-quality services to both enterprises and consumers.