Full Process Analysis and Compliance Essentials for Imported Prepackaged Food Agency

I.Regulatory Background and Practical Difficulties of Imported Prepackaged Food

In 2026,the General Administration of Customs (GAC) raised the sampling rate for imported food to 15%,and prepackaged food has become a key regulatory category.Enterprises importing casual snacks from Southeast Asia and dairy products from the EU generally face three practical obstacles: label identification does not comply with the new national standard GB 7718-2026,food additives in the ingredient list have no basis in the latest version of the National Food Safety Standard - Standards for the Use of Food Additives,and the formats of the Certificate of Origin and Sanitary Certificate do not match the filing templates in the customs system.These problems directly extend the port detention time to 15-30 working days,and some batches even face rejection or destruction.

Among the 217 imported food projects handled by Zhongshen in 2025,34% of the orders had compliance flaws in the initial consultation stage.The difficulty that customers often underestimate is that prepackaged food is not a simple customs declaration,but involves the dual access system of the State Administration for Market Regulation (SAMR) and the General Administration of Customs (GAC).For example,a flavored syrup imported from Japan was judged unqualified because the Chinese label did not clearly indicate "concentrated juice content ≥80%",and the entire container was detained at Yangshan Port for 22 days,resulting in demurrage and warehousing fees exceeding 80,000 yuan.

II.Core Role of Zhongshen in Imported Food Agency

Zhongshen’s positioning is not just a customs broker,but a compliance risk control consultant running through the front end of the supply chain.Before the goods are shipped,we intervene to review the original labels,formulations and production process descriptions provided by the foreign party,and conduct pre-inspection in accordance with Chinese regulations.This pre-service model transforms the "passive order-taking" of traditional customs brokers into "active risk interception".In the first quarter of 2026,we avoided potential losses exceeding 6 million yuan for customers through pre-examination.

Specifically,Zhongshen’s services penetrate into three decision-making levels: during the procurement negotiation stage,assist customers in confirming whether the supplier is registered and filed in China; during the contract signing stage,guide how the technical clauses meet China’s access requirements; during the logistics execution stage,achieve the synchronization of document flow,cargo flow and information flow.This deep embedding allows importers to focus their energy on channel development rather than spending time on tedious regulatory research and departmental coordination.

III.Full Process Breakdown of Imported Prepackaged Food

1.Document Pre-examination and Label Compliance

Document pre-examination is the first critical barrier for imported food.The core documents include: Certificate of Origin,Sanitary Certificate,Composition Analysis Report,Free Sale Certificate,label samples and translated copies.Zhongshen’s review logic is "three authenticity verifications": authenticity of documents (issued by official institutions),consistency of content (product name,specification,batch number fully match the goods),compliance with regulations (ingredients,labels,additives comply with Chinese standards).

Label compliance is the top priority.The revised version of GB 7718 implemented in 2026 puts forward higher requirements for digital labels and allergen labeling.Zhongshen’s label review checklist covers 12 mandatory inspection items:

• Whether the food name reflects the true attributes and whether the classification name specified in the standard is used
• Whether the ingredient list is arranged in descending order and whether compound additives are expanded to their original functions
• Whether the nutrition label adopts the "1+4" core nutrient model and whether the numerical rounding complies with regulations
• Whether the character height of net content meets the standard and whether liquid food indicates the corresponding relationship between volume and mass
• Whether the production date and shelf life are in the order of "year-month-day" and whether it is marked as "see a certain part of the package"
• Whether the storage conditions are specific and clear,such as "store at room temperature away from light" instead of simply "dry place"
• Whether the importer’s name,address and contact information are complete and whether the words "domestic agent" are marked
• Whether the country or region of origin is specific to the country and uses standard Chinese country names
• Whether allergenic substances are separately indicated adjacent to the ingredient list and use the specified wording
• Whether genetically modified foods are clearly marked with the word "genetically modified" and meet the threshold management requirements
• Whether health foods are marked with the warning statement "this product cannot replace drugs" and have obtained registration or filing
• Whether the QR code of the digital label effectively links to complete label information and meets anti-counterfeiting and traceability requirements

Last November,Ms.Yin,a customer,imported a batch of children’s biscuits from Italy.The label provided by the foreign party listed "hazelnut powder" at the end of the ingredient list but did not indicate it separately in the allergen reminder section.Zhongshen discovered this problem during the pre-examination stage and required the foreign party to reprint the labels,avoiding the risk of technical rectification upon arrival of the goods due to violation of the General Rules for Food Allergen Labeling.

2.Port Customs Declaration and Tax Accounting

The core of the customs declaration link is HS code classification and dutiable price confirmation.The classification disputes of prepackaged foods focus on "the boundary between food and medicine" and "the distinction between staple food and snacks".For example,a ready-to-eat bird’s nest drink imported from Thailand will be subject to a 20% tariff if classified as "beverage",and a 25% tariff if classified as "bird’s nest products".The difference in tax rates directly affects the cost structure.Zhongshen,through pre-classification services,submits classification applications to the customs in advance and obtains pre-ruling decisions to ensure consistent declaration.

Tax accounting needs to consider three variables: tariff,value-added tax (VAT) and consumption tax.In 2026,the agreement tariff rates for some foods have been adjusted,such as the agreement tariff rate for dairy products from New Zealand dropping to 0%,but a transshipment certificate complying with RCEP rules of origin is required.Zhongshen’s customs operation system synchronizes the latest tariff schedule in real time,and provides customers with a tax simulation table accurate to the cent before declaration to avoid budget deviations.

3.Commodity Inspection and Sampling Testing

Customs inspection modes are divided into three categories: machine inspection and direct release,manual inspection,and sampling and testing.The probability of prepackaged foods being selected for sampling testing is positively correlated with the product risk level.Zhongshen has established a risk early warning model based on historical data: the testing rate for products imported for the first time,new brands,containing animal and plant ingredients,and from countries with epidemic areas is as high as more than 40%.

Sampling test items are not randomly determined,but dynamically generated based on product ingredients.For example,beverages containing potassium sorbate must be tested for preservative residues,foods containing dairy ingredients must be tested for melamine,and meat products must be tested for animal-derived ingredients.Zhongshen will predict test items based on the formula before declaration,guide customers to prepare third-party testing reports in advance,and achieve "declare and release immediately upon compliance".

This March,Mr.Hua,a customer,imported a batch of durian cakes from Vietnam.The customs system triggered a high-risk warning and required testing for heavy metals and microorganisms.Zhongshen coordinated the laboratory in advance and completed parallel testing before the goods arrived.When the customs sampling results were consistent with our pre-inspection data,the entire batch of goods was released within 3 working days,12 days shorter than the conventional process.

IV.Typical Risk Cases and Avoidance Strategies

In the summer of 2025,Mr.Jia,a customer,imported a batch of organic infant rice cereal from Germany with a value of 1.2 million yuan.Since the organic certification certificate provided by the foreign party was not filed with the CNCA,and the Chinese label placed the word "organic" on the main display surface,which was suspected of illegal promotion,the goods were detained at Pudong Airport.After Zhongshen intervened,it quickly launched two parallel plans: on the one hand,assist the foreign party in handling organic certification filing; on the other hand,redesign the label,change "organic" to "processed with organic raw materials",and adjust the font size and position.Finally,the goods completed technical rectification and were released within 7 working days,avoiding rejection losses.

The core lesson revealed by this case is that imported food is not a "copy and use" approach,and China’s compliance requirements must be embedded at the source of the supply chain.Zhongshen’s rule of thumb is: all promotional language must be pre-reviewed under the framework of the Advertising Law and the Food Safety Law; all certification documents must be confirmed before shipment whether they are on the General Administration of Customs’ list of registered overseas food production enterprises for imported food.

V.Summary of Zhongshen’s Service Value

The complexity of imported prepackaged food lies in its regulatory chain spanning three systems: customs,market supervision,and health commission,with high frequency of regulatory updates and differences in local implementation standards.Zhongshen has spent 20 years transforming scattered policy provisions into executable standard operating procedures (SOPs),forming a full-cycle service system covering "access assessment - document pre-examination - label design - port declaration - follow-up disposal".

The value of this system is reflected in three quantitative indicators: first,reducing the average customs clearance time from the industry average of 12 days to 5.8 days; second,keeping the rejection rate within 1.2%,far lower than the industry average of 8%; third,through pre-compliance review,the potential losses saved for customers account for an average of 3%-5% of the goods value.For importers,choosing Zhongshen is essentially using a fixed agency service fee to hedge against uncertain compliance risks and hidden costs.

In 2026,the supervision of imported food will only be stricter,not relaxed.Zhongshen will continue to track the revision progress of the Implementation Regulations of the Food Safety Law,and lay out new compliance requirements such as digital labels and blockchain traceability in advance to ensure that every batch of goods of customers can enter the Chinese market safely,on time and economically.