Industry Update on China EHCs – August 30

30/08/2017
Industry Update on China EHCs – August 30

Overview

This information note provides an update on the implementation of the Chinese Food Safety Act 2015 and in particular new measures that will apply to food and drink companies which export products to mainland China.

Chinese authorities are seeking to strengthen food supply chain controls in light of strong public concern about food safety. In light of rapidly increasing volumes of food imports into China, and a broadening range of products coming into the market, some of the new controls relate to imported goods.  There are a range of measures, and Defra will provide further updates as the policy and legislation evolve.

This update concerns a specific measure; the proposed introduction of a requirement for harmonised export health certification.  At present exporters seeking to sell animal and plant based products, such as fish, meat, dairy, fruit and vegetables, which are deemed ‘higher risk’, into the China market, must obtain appropriate health certification to accompany their consignments. The new proposal requires that all other food and drink products, exported from any country, into the mainland China market, would need to be accompanied by a new harmonised export health certificate. This would therefore apply to all ambient goods such as alcohol, soft drinks mineral water, snack food, confectionary, condiments and other longer life packaged goods.

This new proposal was recently published for consultation both through the World Trade Organisation, and the website of the Chinese Government Department AQSIQ who are responsible for the control and quarantine of imported goods. The proposal included an implementation date of 1 October 2017.

Update

The UK is, through the European Union, discussing the proposal with the Chinese Government to establish a full set of details about how the new proposal will work. 

Given those discussions are still taking place, the Chinese Government have confirmed that the new measure will not apply from the 1 October 2017 as stated in the consultation and that there will be no disruption to ongoing trade at this time.  The UK is, through the EU, continuing discussions with the Chinese Government about the timing of implementation but our expectation is that the measure will not apply earlier than 1 October 2018.

The Chinese authorities have also confirmed that for those product categories which already require existing plant or animal export health certification, the new requirement for harmonised export health certification will not apply and will therefore not generate any duplication in certification.

The Chinese authorities have also acknowledged that current domestic processes for food safety in the UK are a sufficient basis for providing assurance of compliance for these requirements. As such, our expectation is the UK Government will be able to administer the new certification and no additional checks of exporting companies by the Chinese Authorities will be necessary.

Following discussion with export bodies and industry representatives, we are aware that some products leave the UK long before reaching China and often undergo redistribution through regional hubs.  Defra is engaged in EU discussions with Chinese authorities in order to clarify the process with sufficient lead in time for industry to prepare consignments.

Defra is continuing to work closely with the Chinese authorities, the European Union and key British industry stakeholders to ensure that trade will continue as seamlessly as possible. Defra is working with CBBC, FDF and FDEA to produce a series of workshops to provide more detail on these requirements and the application process for certificates. These workshops will provide an opportunity to ask questions and seek clarification, and details of these sessions will be communicated soon.

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30/08/2017