---
title: "2026 Version of Full Process Operation Guide for Trading Companies Acting as Import Agents for Infant Formula Milk Powder - Zhongshen Trading China"
description: "China's infant formula milk powder imports are expected to exceed 300,000 metric tons in 2026，with New Zealand accounting for over 60% of the total. However，complicated registration and filing，inspection and quarantine，and label review have caused 80% of enterprises to encounter customs clearance delays. Supervisor Zheng of Zhongshen's Import Division points out that the core value of professional agents lies in proactive risk identification and compliance system establishment. This ar..."
url: "https://www.sh-zhongshen.com/en/import-agent-services/trade-company-import-infant-formula-guide-2026.html"
language: "en"
type: "Article"
category: "Import agent"
datePublished: "2026-10-04"
dateModified: "2026-10-04"
brand: "Zhongshen Trading China"
image: "https://cndpic.sh-zhongshen.com/uploads/tradepics/u53pIpksRzLhX.webp"
---

# 2026 Version of Full Process Operation Guide for Trading Companies Acting as Import Agents for Infant Formula Milk Powder

According to China Customs data,infant formula milk powder imports increased by 23% year-on-year in the first quarter of 2026,with products originating from New Zealand accounting for a stable share of around 65%.Behind this figure lies the practical dilemma faced by importers: any error in links including verification of overseas manufacturer registration information,matching of formula registration numbers,Chinese label review,and random inspection of microbial indicators by commodity inspection authorities may lead to entire batches of goods being detained at ports or even returned.In a recent case handled by Supervisor Zheng of Zhongshen’s Import Division,three containers of milk powder imported independently by a Shanghai maternal and infant chain enterprise were judged as "goods inconsistent with documents" by port commodity inspection authorities due to discrepancies between the production batch number on the health certificate and the printed label on the actual goods,directly facing the risk of return.

This scenario is not uncommon in the imported milk powder sector.The bilateral agreement between New Zealand’s Ministry for Primary Industries (MPI) and the General Administration of Customs of China (GACC) updated the verification mechanism for the registered enterprise list in 2026,requiring that the Chinese registration status of overseas manufacturers be re-verified before each batch is imported.Most importers are not aware of this dynamic change and still follow the traditional "ship first,supplement documents later" model.The database established by Zhongshen is connected in real time to the GACC’s overseas food manufacturer information system,and completes the registration validity screening before customers place purchase orders,stopping risks at the source.

![2026 Version of Full Process Operation Guide for Trading Companies Acting as Import Agents for Infant Formula Milk Powder](https://cndpic.sh-zhongshen.com/uploads/tradepics/u53pIpksRzLhX.webp)

## Registration Verification of Overseas Manufacturers and Matching of Formula Registration

For New Zealand infant formula milk powder to enter the Chinese market,manufacturers must obtain a "Chinese Registration Number" from the GACC,and this number must accurately match the "Infant Formula Product Formula Registration Number" issued by the State Administration for Market Regulation (SAMR).According to the new 2026 regulations,the label draft,nutrition composition table,and production process description corresponding to each formula registration number must be completely consistent with the imported actual goods.After receiving an order,Supervisor Zheng’s team first obtains the customer’s intended purchase product information,queries the validity of the registration number in the GACC system,and simultaneously compares it with the special food information inquiry platform of the SAMR to confirm whether the formula registration status is "valid" and "unchanged".

The most common pitfall at this stage is expired registration information.Some small and medium-sized dairy enterprises in New Zealand renewed their production licenses at the end of 2025,and the new Chinese registration numbers took effect in February 2026,but many importers still hold old numbers in their supplier materials.Zhongshen’s verification system is equipped with a 90-day validity warning,which automatically reminds enterprises whose registration numbers are about to expire to update them in time.For the matching of formula registration numbers,the team will verbatim check the product name,stage identification,and printing format of the formula registration number on the Chinese label to ensure that they are completely consistent with the official filing sample.Once an importer’s label printed "formula registration number" as "registration formula number",the two-character difference made the entire batch of goods unsaleable,and this lesson has been incorporated into Zhongshen’s label review SOP.

## Filing of Domestic Consignees and Pre-review of Import Qualifications

After completing the overseas verification,the next step is to confirm the qualifications of the domestic consignee.In 2026,the GACC implemented a dynamic credit rating system for food importer filing.Enterprises with a rating below Grade B importing infant formula milk powder will automatically trigger a strengthened supervision mode,and the inspection rate will be increased to 100%.When receiving an order,Zhongshen will first query the customer’s filing credit rating.For customers with lower ratings,it is recommended to adopt the "double title" mode,that is,use the company’s own high-rated filing qualification as the domestic consignee,and the customer as the actual consumption and use unit.

For domestic consignee filing,12 documents including business license,food business license,and imported food quality and safety management system need to be submitted.Supervisor Zheng’s team has compiled a "List of Documents for One-time Filing Approval",marking the specific requirements,common error points,and official review key points of each document one by one.For example,the business scope of the food business license must clearly include "special food sales (infant formula milk powder)",and only writing "food sales" will be rejected.A new requirement added in 2026 is to provide social security certificates and training records of food safety management personnel,and many enterprises have their filing returned for correction due to ignoring this point.Zhongshen’s pre-review service solves all these problems before formal submission,shortening the average filing cycle from the industry’s general 15 working days to 5 working days.

## Document Pre-review and Compliance Review of Chinese Labels

Entering the document preparation stage,the core documents include certificate of origin,health certificate,composition analysis report,original can label,and Chinese label sample.In 2026,the GACC implemented electronic network verification for health certificates of dairy products exported from New Zealand to China.The authenticity of the certificate can be directly verified in the system,but the consistency between the certificate content and the actual goods still requires manual review.Supervisor Zheng’s team has established a "three comparison" mechanism: comparing the product description on the certificate with the formula registration information,comparing the production date on the certificate with the spray code on the can body,and comparing the quantity on the certificate with the packing list.

![2026 Version of Full Process Operation Guide for Trading Companies Acting as Import Agents for Infant Formula Milk Powder](https://cndpic.sh-zhongshen.com/uploads/tradepics/U6zLB1Qk8ayLU.webp)

Chinese label review is the most technical link.According to the revised version of the Measures for the Administration of Product Formula Registration of Infant Formula Milk Powder implemented in 2026,vague publicity terms such as "imported milk source" and "ecological pasture" are prohibited on labels,and specific geographic information such as "XX Pasture,XX County,New Zealand" must be specified.There are detailed regulations on the rounding interval of the nutrition composition table,the expression method of functional claims,and the font size requirements of warning terms.Zhongshen’s label review system has a built-in rule engine,which automatically detects illegal expressions in label drafts.Once a New Zealand milk powder label used the words "close to breast milk",the system flagged it as a high-risk expression during the pre-review stage,and suggested modifying it to "simulate breast milk fat structure",avoiding the risk of penalties after launch.

- The health certificate must indicate the registration number of the pasture where the dairy raw materials come from
- The composition analysis report must include special test data for chlorate and perchlorate
- The Chinese label must indicate the product category attribute "infant formula milk powder" instead of "milk powder"
- The batch number on the original can label must be completely consistent with the batch number on the affixed Chinese label

## Key Nodes of Port Customs Declaration,Classification and Valuation

The core challenges in the customs declaration link lie in tariff code classification and dutiable value determination.Infant formula milk powder may be classified into different tariff codes such as 0402.2100 and 0402.2900 according to subdivision characteristics such as stage,whether it contains lactose,and whether it contains hydrolyzed protein,with the maximum tax rate difference reaching 8 percentage points.In 2026,the GACC issued a dairy product classification guideline,which clearly added a special tariff code for "partially hydrolyzed protein infant formula milk powder".Before customs declaration,Zhongshen will obtain detailed product process descriptions from customers,and request New Zealand manufacturers to provide production flow charts when necessary to ensure accurate classification.

In the valuation link,the import dutiable value of New Zealand milk powder usually includes FOB price,sea freight,and insurance premium,but many importers ignore whether the "dairy export levy" and "organic certification fee" imposed by the MPI should be included in the dutiable value.Supervisor Zheng’s team will analyze the nature of expenses item by item according to the Measures for the Customs Determination of Dutiable Value of Import and Export Goods.For expenses that should not be included in the dutiable value,legal basis and supporting materials will be provided in the remarks column of the customs declaration form to strive for a reasonable dutiable value for customers.In February 2026,a customer mistakenly included marketing expenses in the dutiable value,resulting in overpaid tax of nearly 300,000 yuan.Zhongshen found the problem in the subsequent document review and assisted the enterprise in applying for tax refund from the customs.

## Response Strategies for Commodity Inspection and Sampling Testing

Infant formula milk powder is a high-risk food,and the port inspection rate has remained above 30% all year round.In 2026,the GACC implemented an upgraded version of the "double random,one public" system for New Zealand milk powder,where inspection instructions are randomly triggered by the system,and the entire inspection process is recorded on video.Zhongshen’s on-site port team has established a regular communication mechanism with customs in multiple regions,and obtains key inspection prompts as soon as the inspection instruction is issued.For random inspection of microbial items,the team will check the factory inspection report of the batch in advance.For easily fluctuating indicators such as total bacterial count and coliform bacteria that are close to the standard limit,customers are advised to actively apply for re-inspection or rectification.

The most tricky part is the monitoring of Cronobacter sakazakii and Salmonella.According to the new 2026 regulations,only when products of the same registered enterprise pass 5 consecutive batches of random inspection can the sampling frequency be reduced from each batch to every three batches.Zhongshen has established batch traceability files for customers.When a product of a certain manufacturer fails the random inspection,the import of other batches of goods from that manufacturer is immediately suspended to avoid chain reactions.Supervisor Zheng once handled a case: a New Zealand brand milk powder was tested positive for Cronobacter sakazakii,and the customer faced the return of the entire batch.By checking the production records,the team found that the problematic batches and qualified batches used different batches of whey powder raw materials,and finally persuaded the customs to only return the problematic batches,recovering nearly 80% of the goods value for the customer.

| Process Stage | Average Time Consumed | Main Risk Points | Core Value of Professional Agents |
| --- | --- | --- | --- |
| Registration verification of overseas manufacturers | 15-20 working days | Expired registration information,unfiled formula changes | Real-time database comparison,30-day advance warning |
| Filing of domestic consignees | 5-7 working days | Incomplete filing materials,too low credit rating | One-time document list,100% pre-review pass rate |
| Document pre-review and label review | 3-5 working days | Inconsistent health certificate,illegal label expressions | Rule engine automatic detection,templated review |
| Port customs declaration and valuation | 1-2 working days | Incorrect tariff code classification,overestimated dutiable value | Pre-classification service,item-by-item analysis of expense nature |
| Commodity inspection and sampling | 7-10 working days | Excessive microorganisms,label defects | Sampling plan optimization,pre-positioned rectification plan |
| Warehousing,distribution and traceability | 2-3 working days | Out-of-control temperature and humidity,batch confusion | Constant temperature and humidity warehouse,code scanning traceability system |

## Warehouse Management and Follow-up Traceability Support

The warehousing link after customs clearance and release is also critical.Infant formula milk powder must be stored in an environment of 0-25and relative humidity below 60%,and cannot be mixed with items with peculiar smells.Zhongshen has dedicated constant temperature warehouses in Shanghai Waigaoqiao and Yangshan Port,equipped with 24-hour temperature and humidity monitoring systems and abnormal alarm devices.When each batch of goods is put into storage,the team will record the can spray code,production batch,storage time,and location number,establish an electronic location card,and realize first-in-first-out management.

In 2026,the SAMR requires imported infant formula milk powder to establish a "one product,one code" traceability system,where consumers can scan the code to query the full chain information of the product from overseas production to domestic sales.Zhongshen assists customers in entering information such as customs declaration number,inspection and quarantine certificate number,and warehouse outbound records into the traceability platform to generate qualified QR codes.Supervisor Zheng reminds customers that traceability information must be entered before the product is launched for sale,otherwise it will be regarded as failing to establish a traceability system as required,and face a fine of less than 50,000 yuan.

In the fourth quarter of last year,after a batch of New Zealand milk powder imported by Zhongshen as agent was launched for sale,some consumers complained that the cans had slight dents.The customer was worried about affecting the brand reputation and was preparing to remove all products from the shelves.Supervisor Zheng’s team retrieved the transportation monitoring records of the batch and found that the dents were an individual phenomenon caused by insecure fixation in the sea container,not a regular quality problem.The team assisted the customer in issuing a third-party test report,proving that the dents did not affect the product sealing and nutritional components,helping the customer avoid unnecessary recall losses.

From registration verification of overseas manufacturers to domestic sales traceability,every link of infant formula milk powder import is embedded with regulatory requirements and technical details.Zhongshen has disassembled this process into 127 standard operating steps over 20 years,with corresponding checklists and risk plans for each step.Data shows that enterprises using professional agency services have an average customs clearance time 15 working days shorter than that of independent import,and the return rate caused by compliance issues has dropped from the industry average of 8% to less than 1%.For importers,choosing agency services is not simple affair outsourcing,but transforming uncontrollable compliance risks into budgetable fixed costs.In the market environment of stricter supervision in 2026,this transformation is particularly necessary.

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