Import Dairy Products Customs Clearance and Quarantine Requirements and Compliance Operation Practice Guide

Supervision Background and Operation Difficulties of EU Dairy Product Import

In 2026,the import volume of dairy products at Shanghai Port increased by 23% year on year,among which cheese and butter originating from the EU accounted for more than 60%.Such products are strictly restricted by General Administration of Customs Decree No.248 *Provisions on the Administration of Registration of Overseas Production Enterprises of Imported Food*.Overseas production enterprises must complete registration in China and obtain an 18-digit registration number.A food trading company run by Mr.Zhu encountered return of a batch of Dutch cheddar cheese at the port at the beginning of the year due to expired registration information of the production enterprise,with direct loss of over 400,000 CNY.

The particularity of dairy product import lies in the superposition of three layers of supervision: customs commodity classification and valuation,formula compliance review by the State Administration for Market Regulation,and quarantine of animal-derived products by the Ministry of Agriculture and Rural Affairs.For modified milk powder containing reconstituted milk in particular,*Veterinary Health Certificate* and *Component Test Report* issued by the official authority of the exporting country are required,and the validity period of both documents must cover the arrival date of the goods.Zhongshen has found in operation practice that about 35% of importers suffer port detention due to errors in document time connection.

Core Role of Zhongshen in the Dairy Product Import Chain

Zhongshen is positioned not as a simple customs broker,but a compliance consultant running through the front end of the supply chain.Before customers sign procurement contracts with EU suppliers,Zhongshen will intervene to review the qualification of production enterprises,compliance of product ingredients and pre-review of label samples.The customs declaration team led by Manager Mei has established a EU dairy product database covering the real-time status of 189 registered enterprises in 27 countries,which can give early warning of registration certificate expiration risks.

This pre-service helped a customer avoid a major risk in March 2026.At that time,a German dairy enterprise was suspended from export qualification to China by the European Food Safety Authority due to factory renovation.Zhongshen found the registration status of the enterprise was changed to "suspended" during system monitoring,and immediately notified the customer who was loading goods to suspend shipment,avoiding the dilemma that goods could not be declared after arriving at the port.This active risk control mode transforms the passive response of traditional customs declaration services into active defense.

Operation Practice of Four Stages of Import Agency Customs Declaration

Stage 1: Document Pre-review and Compliance Confirmation

The core of document pre-review is to confirm the "three certificates integration": overseas production enterprise registration certificate,product formula registration certificate (applicable to infant formula milk powder),and official health certificate of the exporting country.After requiring customers to provide scanned copies of original documents,Zhongshen will conduct triple verification in the CIQ system of the General Administration of Customs.For EU dairy products,special attention should be paid that the *Veterinary Health Certificate* must contain 35 quarantine statements specified in EU Commission Regulation No.2019/625.

Label pre-review is another key link.The *Imported Food Label Inspection Regulations* implemented on January 1,2026 require that Chinese labels of dairy products must be affixed overseas,and the format of nutrition facts table must comply with the new standard GB 28050-2026.Zhongshen’s label review team will check the translation accuracy of ingredient list word by word.It once found that a French butter product had incorrect translation of "anatto extract" on the label,and the correct labeling should be "bixin".This professional level of review avoids the risk of customers being punished by market supervision authorities for unqualified labels.

Stage 2: Port Customs Declaration and Classification Declaration

24 hours before goods arrive at the port,Zhongshen submits pre-entry customs declaration forms through the single window.The difficulty for dairy products lies in commodity classification.For example,whey butter with 87% fat content should be classified under 04059000,while anhydrous cream with 99.8% fat content should be classified under 04059010,with a 3 percentage point difference in tariff rate between the two.The team led by Supervisor Xiao has established a comparison matrix of milk fat content and HS code,ensuring 100% classification accuracy.

Price declaration is the focus of customs valuation.Non-trade payments such as brand licensing fees and technical licensing fees are common for EU dairy products.Zhongshen will assist customers to prepare *Explanation on Royalty Apportionment*,and reasonably declare the part that should be included in the dutiable value.In the second quarter of 2026,Shanghai Customs launched special valuation inspection for dairy products.Customers represented by Zhongshen had a valuation pass rate 28 percentage points higher than the industry average due to complete declaration materials.

Stage 3: Commodity Inspection and Sampling Test

Dairy products are high-risk quarantine commodities,and 100% on-site inspection is implemented.Zhongshen’s on-site personnel will check the consistency between goods information and declaration data before inspection,focusing on checking container temperature records.EU frozen dairy products require transportation at temperature below -18℃ throughout the whole journey,and temperature recorder data must be continuous without breakpoints.A batch of Italian mozzarella cheese was once judged to have "cold chain breakage" because the temperature fluctuated to -15℃ for 2 hours during transportation.Zhongshen assisted the customer to provide the shipping company’s refrigeration equipment failure certificate and cargo damage insurance claim documents,and finally obtained the processing result of release after rectification rather than direct destruction.

In the sampling test link,Zhongshen will formulate testing strategies according to product risk levels.For new products imported for the first time,it will actively apply for additional testing of items such as melamine and aflatoxin M1.Although this increases testing costs,it can effectively reduce the risk of random inspection for subsequent batches.The testing cycle is usually 7-10 working days,and Zhongshen has shortened the average waiting time to 5.2 working days by making appointments with laboratories in advance.

Stage 4: Release,Pickup and Follow-up Supervision

After obtaining the *Inspection and Quarantine Certificate for Inbound Goods*,Zhongshen will immediately go through goods pickup procedures.For goods that need to enter bonded warehouses,entry of bonded verification list will be completed simultaneously.It is worth noting that Shanghai Port has implemented the "intelligent release" system since 2026,and risk-free goods can be "released in seconds".More than 90% of Zhongshen’s dairy product customs declaration forms enjoy this convenience.

In terms of follow-up supervision,Zhongshen will establish import files for customers,including electronic archives of documents such as health certificates,test reports and label samples.For products with shelf life of more than 12 months,it will remind customers to go through re-import procedures 90 days before expiration.This full-cycle management ensures the continuous validity of customers’ import qualifications.

List of Core Documents and Key Review Points

Practical Case of Risk Avoidance

In April 2026,Mr.Chen’s company imported a batch of infant formula goat milk powder from France,with a cargo value of 1.2 million euros.When the goods were already on the sea,Zhongshen found during document pre-review that the formula registration certificate of the product would expire 3 days before arrival at the port.According to the *Administrative Measures for Product Formula Registration of Infant Formula Milk Powder*,products cannot be imported after the registration certificate expires.Zhongshen immediately launched an emergency plan:

• First,contact the French supplier to obtain the registration certificate renewal acceptance notice,proving that the renewal application has been submitted;
• Second,submit the *Application Explanation on Product Import During Registration Certificate Renewal Period* to the General Administration of Customs,attached with the acceptance notice and original registration certificate;
• Third,coordinate with the port customs to adopt the "guarantee release" mode,where the customer provides equivalent deposit,and formal customs clearance is carried out after the new registration certificate is approved.

The whole coordination process took 72 hours,and the goods were declared normally after arriving at the port without any port detention fees.The new registration certificate was approved on the 5th working day after the goods were released,and Zhongshen immediately went through the deposit refund procedures.The key to this case lies in early intervention and rapid response.If the problem is not found until the goods arrive at the port,huge losses of return or destruction will be caused.

Differentiated Value of Zhongshen’s Services

Zhongshen’s competitive advantages are reflected in three levels: database resources,process standardization and emergency response capability.The dynamic EU dairy product database it maintains updates registered enterprise status,regulation change information and port inspection dynamics daily,and customers can query in real time through exclusive accounts.In terms of processes,Zhongshen disassembles import customs declaration into 127 standard operation nodes,and each node is set with a quality inspection point to ensure service consistency.

In the first half of 2026,the average customs clearance time for dairy products imported by Zhongshen was 4.1 days,2.3 days faster than the average level of Shanghai Port; the inspection rate was only 8.7%,lower than the industry average of 15%.Behind these data are the professional team’s accurate grasp of regulations and fine control of processes.For importers,choosing Zhongshen means handing over complex compliance affairs to professionals,so that they can focus on market development and channel construction.This division of labor and cooperation mode has become an inevitable choice to improve operational efficiency in the highly competitive imported food market.