What Qualifications and Access Conditions Must Enterprises Meet for Importing Functional Food Ingredients?

Mr.Tan,head of a health food manufacturing enterprise in Shanghai,recently plans to import a batch of collagen peptide raw materials containing new ingredients from Japan.Despite the promising market prospect,Mr.Tan has encountered successive obstacles in preliminary consultation: Are the documents provided by the Japanese supplier compliant with the requirements of China Customs?Does this new raw material require additional approval from the national competent authority?How should the product label be designed to pass the audit at one time?These seemingly trivial issues are directly related to whether the entire batch of goods can enter the Chinese market smoothly.Mr.Tan’s dilemma is not an isolated case.At present,when enterprises import goods such as food ingredients,cosmetic base materials and medical devices from Japan,Europe and the United States,they are first confronted with a complex network of qualification requirements covering access permits,ingredient standards,enterprise filing,label specifications and other aspects.

When handling similar import business,Zhongshen first acts as a "compliance screener".Our work starts before the contract is signed,with the core of helping customers identify and confirm all necessary access qualifications.Taking functional food ingredients as an example,the process is far more than just applying for an Import Goods Declaration Form.Its compliance chain extends to multiple links before,during and after import,and the omission of any link may lead to a complete halt of the whole process.

Process-based Disassembly and Response to Import Qualification Requirements

We divide the whole process of importing a shipment of Japanese functional food ingredients into three key stages,each with its unique qualification thresholds and review priorities.

Stage 1: Access and Document Pre-review

This stage determines whether the goods are eligible for import declaration to China.The core qualifications include:

• Registration of overseas production enterprises: Japanese production plants must register with the General Administration of Customs of China and obtain a registration number.This is the access threshold,and no import is allowed without a valid registration number.
• Importer filing: The Chinese import enterprise where Mr.Tan works needs to complete the filing of imported food consignee with the market supervision authority in advance.
• Ingredient compliance judgment: If collagen peptide belongs to new food raw materials or involves health function claims,it is necessary to check whether it has been included in the list of available raw materials issued by the National Health Commission of China,or whether a New Food Raw Material License is required.
• Review of accompanying documents: The format,seal and testing items of the official Certificate of Origin,Sanitary Certificate or Phytosanitary Certificate issued by Japan must fully meet the requirements of the Chinese side.Based on the latest regulation database,Zhongshen’s customs staff will pre-review the draft documents provided by the supplier,point out non-conforming items,and require the Japanese side to make corrections before shipment,so as to eliminate document problems from the source.

Stage 2: Port Customs Declaration and Tax Payment

After the goods arrive at Shanghai Port or other designated ports,formal customs declaration shall be made.The core of this stage is to ensure that the declaration information is consistent with the actual goods and documents,that is,"documents are consistent with each other,and documents are consistent with goods".

Functional food ingredients are usually subject to statutory inspection and quarantine.When declaring,in addition to submitting trade documents such as contracts,invoices,packing lists and bills of lading,access qualification documents such as foreign official sanitary certificates and certificates of origin must also be attached.The customs will focus on reviewing the following aspects:

The accuracy of commodity classification (HS code) is directly related to the applicable supervision conditions (such as whether an Import License is required),tariff rate and value-added tax rate.Incorrect classification may lead to tax repayment,penalties,or even transfer to anti-smuggling department on suspicion of evading license management.Relying on years of commodity database and classification experience,Zhongshen’s customs declaration team will complete accurate classification before declaration,and judge accordingly whether it is necessary to apply for Import License or other approvals for customers.

The inspection process is the materialization of qualification review.The customs or market supervision authority may conduct sampling testing to verify whether indicators such as nutritional components,additives,pollutants and microorganisms meet China’s national standards (GB standards).If the test fails,the goods will be returned or destroyed.Our value lies in avoiding known high-risk items in advance through preliminary ingredient pre-evaluation and supplier qualification screening,so as to reduce the probability of non-conformity in port inspection.

Stage 3: Destination Inspection and Warehousing

After port release,the goods are transferred to the destination warehouse.For food ingredients,importers also need to establish complete import records and sales records to realize product traceability.When the market supervision authority conducts follow-up market sampling inspection,the enterprise must be able to provide the full set of import qualification certification documents of the batch of goods at any time,including the customs release note,inspection and quarantine certificate of entry goods,etc.

Zhongshen will file and sort out the full set of documents for each import business for customers,forming clear archives.When Mr.Tan needs to respond to customer audits or market supervision spot checks,we can quickly retrieve the complete compliance evidence chain.

Qualification Risk Avoidance from Practical Cases

Last year,a customer we served planned to import a batch of Japanese plant extracts for cosmetics production.The customer initially believed that since the product had obtained the cosmetic raw material certification in Japan,there should be no obstacles to import.However,our customs manager found during pre-review that although a solvent component of the extract is listed in China’s Catalogue of Used Cosmetic Raw Materials,there are specific restrictions on its purity,while the specification provided by the Japanese side did not specify this indicator.

We immediately suspended the customs declaration process,and suggested that the customer require the Japanese side to provide the purity test report of the solvent component,or replace it with an alternative solvent without restriction requirements in the catalogue.At the same time,we communicated with the customs technical department in advance,and clarified the testing requirements and qualification standards under this circumstance.Finally,the Japanese side supplemented the test report that met the requirements,and the goods were released smoothly after sampling verification at the port.This case shows that the in-depth understanding of qualification requirements lies not only in knowing what documents are needed,but also in being able to predict the compliance risks that may be caused by the subtle technical clauses in the document content and intervene in advance.

For importers like Mr.Tan,it is extremely high in time cost and trial-and-error risk to set up their own team to track and study the ever-changing global access lists,China’s national standards,customs classification rulings and quarantine requirements.The value of professional import agents is to transform such scattered,complex and dynamic compliance knowledge into stable and executable import operation processes.

With more than 20 years of in-depth industry experience,Zhongshen has accumulated a huge compliance database and case library covering mainstream products and countries.We act as a navigator for enterprises in the maze of import qualifications.Through forward-looking compliance planning,precise document control and professional port communication,we eliminate potential customs clearance obstacles invisibly,ensure the certainty and timeliness of the import supply chain,and allow enterprises to focus their resources on market and research and development.