Feed and Pet food Import Compliance Analysis

Background

Feed refers to products that are processed and manufactured industrially for animal consumption. This includes single feed, additive premixed feed, concentrated feed, formula feed, and concentrate supplements. It also encompasses live animals used as bait, ice-fresh or frozen animal and aquatic products for feed (including bait), processed animal protein and fats, pet food and chews, forage, silage, grain feed, bran and meal residues, processed plant protein and plant powders, formula feed, and additive premixed feed, among others.

According to the Administrative Measures on Feed and Pet Food, pet feed specifically refers to feed for pet dogs and cats. It is a type of feed that falls into three categories: formula feed, additive premixed feed, and other pet feed.

Category	Definition	Examples of common names
Pet formula feed (usually referred to as main pet food)	Feed formulated by mixing various feed ingredients and feed additives in certain proportions; Capable of meeting the comprehensive nutritional needs of pets	Complete Nutrition Pet Food for Dogs; Complete Nutrition Puppy Food; Complete Nutrition Pet Food for Teddy Puppies; Pet Prescription Food Dog Formula Feed
Additive premixed feed (usually referred to as pet health foods)	Meets the nutritional needs of pets for nutritional feed additives (such as amino acids, vitamins, mineral trace elements, enzyme preparations, etc.); Formulated by mixing nutritional feed additives with carriers or diluents in certain proportions	Pet Additive Premixed Feed Trace Elements; Pet Nutrition Supplement Vitamin B; Supplementary Pet Food Trace Elements for Large Breed Puppies
Other pet feed (usually referred to as pet snacks)	For the purpose of rewarding pets, engaging with them, or stimulating chewing, tearing, and other behaviors; Formulated by mixing several feed ingredients and feed additives in certain proportions	Pet Snack Meat Stick; Pet Snack Puppy Beverage; Pet Snack Puppy Beef Bites; Pet Snack Puppy Dental Chews; Pet Snack Teddy Pet Chew

• Click here to learn about MARA Imported Feed and Pet Food Registration.
• Click here to learn about the General Administration of Customs of the People’s Republic of China (GACC) Registration Service of Overseas Manufacturer of Imported Feed and Pet Food.

Compliant Procedures of Pet Food Import

Imported Pet Food Labeling

The packaging of imported pet feed must feature labels in Chinese that comply with the Pet Feed Labeling Regulations. Customs officials will verify these labels during on-site inspections, and, if the labels fail to meet the requirements and cannot be corrected, the feed will be either returned or destroyed.

Feed operators are not allowed to unpack, repackage, reprocess, or add any substances to pet feed products.

Sanitary Standards for Imported Pet Food

The sanitary standards for imported pet feed products must comply with the provisions specified in the Pet Feed Sanitary Regulations. Customs officials may randomly sample different types of pet food and send them to a lab for safety and health testing. Products that fail to meet the requirements will be subject to return or destruction.

Countries Granted Access

GACC sets inspection and quarantine requirements for imported feed products based on their types. For countries or regions exporting feed to China for the first time, a risk analysis is conducted. For countries or regions that have previously or are currently exporting feed to China, a retrospective review is performed, focusing on their feed safety regulatory systems. Based on the results of the risk analysis or retrospective review, the list of countries or regions and types of feed products permitted for import is developed, adjusted, and published.

Therefore, the first step for businesses is to check whether the country of origin and pet food are included in the List of Countries (Regions) and Products Allowed for Feed Import. As of August 14, 2020, the latest catalog of countries permitted for pet food access is List of Countries (Regions) and Products Allowed for Feed Import (Excluding Plant-Based Feed Ingredients) (Updated 20200518). According to this catalog, 18 countries (regions) whose pet food is listed and allowed for import are as follows: Thailand, China Taiwan, the Philippines, Uzbekistan, the Netherlands, France, Belgium, Germany, Denmark, the Czech Republic, Italy, Austria, the United States, Canada, Brazil, Argentina, New Zealand, and Australia.

Taking Asia as an example, pet food from Thailand has been granted access, whereas that from Japan has not yet been included in the list of approved countries. In other words, pet food from Thailand is eligible for export to China, while that from Japan has not yet received permission.

Registration of Overseas Pet Food Manufacturers

GACC implements a registration system for manufacturers in countries or regions permitted for feed import. Imported feed should come from registered overseas manufacturers.

Therefore, after confirming the country’s access, it is also necessary to verify if the pet food manufacturer is included in the List of Registered Overseas Pet Food Manufacturers in that country. According to the latest List of Registered Canadian Pet Food Manufacturers for Export to China (Updated March 17, 2020) as an example, there are currently 9 registered manufacturers. The list specifies the types of pet food each enterprise is allowed to export to China. Some enterprises are only permitted to export pet dry food, while others are authorized to export pet snacks exclusively.

Applying for Import Animal and Plant Quarantine Licence

An Animal and Plant Quarantine Licence for imported feed should be obtained as per regulations. Pet food, particularly formula feed, falls under animal-origin feed, requiring the Permit prior to import. However, according to Announcement on the Cancellation of Quarantine Approval for Certain Imported Products (GACC Announcement No. 51 of 2018), canned cat and dog food no longer need this Permit, despite being animal-origin feed.

Imported Feed and Pet Food Registration

Overseas pet feed manufacturers exporting formula feed or pet additive premixed feed to China must register with the Chinese agricultural authority through their local offices or agents and obtain an import registration certificate. Click here for details on the registration process, required documents, timeline, etc.

Our services

Pet Food Formula Compliance Analysis

• Identify pet food categories;
• Assess the availability of feed ingredients and additives in the formula, and confirm if the quantities are compliant; and
• Provide recommendations if there are any non-compliant situations.

Pet Food Label Review

• Identify pet food categories;
• Review the original and Chinese labels, and provide feedback; and
• Assist in designing the standard labeling if there are Chinese labels.

Imported Feed and Pet Food Registration Certificate

• Apply for the import registration certificate on behalf of the client;
• Carry out sample customs clearance and testing, etc.

Other services

• NHC New Food Raw Material Registration in China
• NHC New Food Additive Registration in China
• Genetically Modified Microorganism Food Additive Registration in China
• SAMR Food for Special Medical Purpose (FSMP) Registration