Full Analysis of Qualification Requirements and Operating Procedures for Imported Brand Agency

Real Dilemmas of Importing Infant Formula from Europe

In Q1 2026,the domestic infant formula market size is expected to exceed 220 billion yuan,with European brands imported through formal agency channels accounting for more than 35%.Manufacturers in the Netherlands,Germany,Ireland and other places have become increasingly strict in qualifying domestic distributors,and many small and medium-sized enterprises are rejected at the initial contact stage.Even after obtaining brand authorization,subsequent links such as factory audits,formula registration,label review and port commodity inspection will make companies without professional teams struggle.

Mr.Qu encountered such a situation at the end of 2025.His maternal and infant products company had just signed a regional agency agreement with a German organic milk powder brand,and the first batch of goods worth about 800,000 euros was ready for shipment.When the goods arrived at Shanghai Yangshan Port,customs inspection found that the format of the nutrition label on the Chinese label did not meet the latest GB 10765-2025 standard,and the entire batch was detained.What was more tricky was that due to unfamiliarity with foreign exchange management regulations,the contract elements submitted when paying for foreign exchange were incomplete,resulting in the bank refusing to handle foreign currency purchase.The goods were detained at the port for a full 23 days,and the detention fees and storage fees almost ate up all the expected profits.

Practical Role of Zhongshen in the Import Agency Chain

Import agency is not just about running errands for customs declaration.The core value of professional institutions like Zhongshen lies in integrating scattered cross-border processes into predictable and controllable standardized services.Taking infant formula as an example,from signing the agency agreement with the brand to final product listing,it involves 14 key nodes,each with clear legal basis and operating window.The agency needs to connect six parties at the same time: overseas suppliers,domestic distributors,customs,market supervision administrations,foreign exchange administrations and transportation companies.Information delay or error from any party may cause the entire chain to break.

Zhongshen’s operation team usually intervenes before the formal signing of the contract.They will review whether the basic documents provided by the brand,such as formula registration certificates,overseas manufacturer registration numbers and product inspection reports,are complete and valid.At the same time,according to the business scope of the domestic distributor’s business license,they will judge whether it is necessary to add the qualification of "special food sales".This pre-review mechanism can reduce sudden problems in subsequent customs clearance by more than 70%.The revised version of the "Regulations on the Administration of Registration of Overseas Manufacturers of Imported Foods" implemented in 2026 requires agencies to establish and dynamically update overseas manufacturer files,which further raises the access threshold for professional agencies.

Full Process Breakdown and Compliance Key Points of Import Agency

Phase 1: Document Pre-Review and Qualification Matching

Before the goods are shipped,Zhongshen will require customers to provide three types of core documents: brand authorization letter,overseas manufacturer registration certificate and product formula registration certificate.These documents need to undergo triple verification: first,confirm the completeness of the authorization chain,that is,whether the brand has authorized the domestic general agent and whether the general agent allows sub-authorization; second,check whether the overseas manufacturer registration number is in the valid list published by the General Administration of Customs of China; finally,check whether the product name,specification and formula on the product formula registration certificate are completely consistent with the actual goods.

The Chinese label pre-review for infant formula is the top priority in this phase.The 2026 new regulations require that all content on the label,including nutrition labels,eating methods,storage conditions,warning statements,etc.must be submitted to the local customs for compliance review in advance.Zhongshen’s label review team will compare the original text and the translation word by word,focusing on checking whether the energy units are marked with kilojoules (kJ) and kilocalories (kcal) side by side,whether vitamin A is marked with retinol equivalent at the same time,and whether legal warning statements such as "the most ideal food for infants aged 0-6 months is breast milk" are omitted.This process usually takes 5-7 working days.After finding problems,it is also necessary to communicate with overseas factories to modify the design draft and reprint the labels.

Phase 2: Port Customs Declaration and Classification Valuation

After the goods arrive at the port,the core of the customs declaration link is accurate classification and reasonable price declaration.The HS code for infant formula is generally 0402.21 or 0402.29,depending on the fat content and whether it contains sugar.The most-favored-nation tariff rate in 2026 is 15%,but products from some countries that have signed free trade agreements with China (such as New Zealand) can apply for 0 tariff.Zhongshen’s customs staff will help enterprises choose the optimal tax rate application plan according to the agreed tariff terms on the certificate of origin.

Valuation is another high-risk point.Customs has a clear reference range for the dutiable price of infant formula.If the declared price is lower than 30% of the average price of similar goods in the same period,the system will automatically trigger manual valuation.Zhongshen will prepare materials such as price certificates issued by the brand,screenshots of overseas market retail prices,international freight and insurance documents in advance to prove the authenticity and reasonableness of the declared price.In 2026,customs has strengthened the review of royalties (such as trademark usage fees).If the agency agreement agrees to collect brand usage fees based on sales,this part of the cost also needs to be included in the dutiable price.

Phase 3: Sampling Inspection and Label Rectification

Infant formula is a high-risk food,and each batch of goods must undergo port inspection.Zhongshen will prepare samples in advance in the sampling area designated by customs,and cooperate with inspectors to randomly select 6-9 cans of products for laboratory testing.The testing items include basic nutrients such as protein,fat and carbohydrates,as well as safety indicators such as melamine,heavy metals and microorganisms.In 2026,testing requirements for chlorate and perchlorate have been added,and the testing period has been extended from the original 15 working days to 20 working days.

If the label is not fully rectified during the pre-review phase,the port customs will require on-site rectification.Zhongshen will set up a label rectification area in the port bonded warehouse,equipped with professional label printing equipment and fitting tools.The rectification process must be completed under customs supervision.The rectified products need to be photographed and archived again,and can only be released after being confirmed by customs officers.The storage fees,labor costs and label materials generated during this process need to be included in the import cost.According to Zhongshen’s 2025 statistical data,about 12% of infant formula batches need port label rectification.

Actual Case: Agency Operations to Avoid Compliance Risks

In February 2026,a Zhejiang maternal and infant chain enterprise served by Zhongshen planned to import an Irish brand of infant formula.During the document pre-review phase,the agency team found that the formula registration certificate provided by the brand would expire in 3 months.According to regulations,goods produced after the certificate expires cannot be cleared.Zhongshen immediately activated an early warning mechanism: on the one hand,it urged the brand to apply for renewal to the State Administration for Market Regulation as soon as possible; on the other hand,it adjusted the shipping plan,advancing the originally scheduled April shipment to mid-March,to ensure that the production date of the goods falls within the validity period of the certificate.

In the label review link,Zhongshen found that the original label design marked the nutrient content of "DHA" and "ARA" below the ingredient list,while the 2026 new regulations require that these optional ingredients must clearly mark their content in the main table of the nutrition label.The agency team provided a label template that meets the new national standards,and assisted in communicating with the design department of the Irish factory,completing the label revision and printing within two weeks.After the goods arrived at Shanghai Waigaoqiao Port,customs inspection took only 1.5 working days to complete sampling,and the laboratory testing period was also reduced to 18 working days,5 days faster than the conventional process.

More importantly,in the foreign exchange payment link,Zhongshen guided the enterprise to prepare complete customs declarations,contracts,invoices and transportation documents according to the requirements of the "Customs Declaration Form Electronic Information Verification Mechanism",and conducted electronic information verification in advance through the "Digital Foreign Exchange Administration" platform.After receiving the foreign currency purchase application,the bank completed the authenticity review and handled the payment on the same day,avoiding the risk of order cancellation caused by inconsistent documents.The total time from arrival at the port to warehousing of the entire batch of goods was 29 days,nearly half shorter than the customer’s historical record of self-operation.

Summary of the Core Value of Zhongshen’s Agency Services

The complexity of importing infant formula lies in the multi-headed management of regulations and the dynamic update of standards.Zhongshen has established an internal knowledge base to track policy changes of the General Administration of Customs,the State Administration for Market Regulation and the National Health Commission in real time,and transform fragmented compliance requirements into executable operation lists.This professional ability is directly translated into cost savings for customers: according to 2026 industry data,professional agencies can shorten the average customs clearance time from 40 days to 25 days,and reduce the loss rate caused by compliance risks from 8% to less than 1.5%.

For enterprises that want to act as imported brand agents,choosing Zhongshen means obtaining a proven cross-border supply chain solution.The agency not only handles documents and customs declaration,but more importantly,acts as a risk buffer to identify and resolve potential compliance obstacles in advance.Against the background of increasingly strict regulatory environment in 2026,this professional division of labor is no longer an optional option,but a necessary investment to ensure business continuity.When enterprises can focus their energy on channel construction and brand marketing,and hand over the complex import process to professional teams,the profit model of the entire agency business will truly work.

• Imported infant formula must obtain both overseas manufacturer registration number and formula registration certificate qualifications
• Chinese labels must be submitted for review in advance,and the format of the nutrition label must meet the GB10765-2025 standard
• Customs strengthened the review of royalties in 2026,and trademark usage fees need to be included in the dutiable price
• Port inspection has added testing requirements for chlorate and perchlorate,and the testing period has been extended to 20 working days
• The State Administration of Foreign Exchange requires verification of electronic customs declaration form information,and payment documents must be complete and consistent
• The qualification of "special food sales" must be clearly listed in the business scope of the business license