Is it mandatory to label domestic agent information on imported pre-packaged food labels? What are the compliance requirements?

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I am an entrepreneur who has been in the industry for half a year and mainly imports Japanese internet-famous snacks. Last month, I shipped 200 cases of sandwich cookies from Kobe to Shanghai Yangshan Port for the first time. During customs clearance, on-site inspection by the customs pointed out that the pre-packaged food label did not indicate the domestic agent information, and the goods were directly detained in the port area.

It took a full 7 days to rush to revise the label and submit supplementary materials before release. The detention fees and label revision fees alone cost nearly 20,000 yuan, and I also missed the 618 promotion period of the e-commerce platform, suffering heavy losses. This week, I will ship another 300 cases of matcha chocolate beans. I heard that the local market supervision bureau now strictly inspects imported food labels in offline supermarkets and online platforms.

I am worried that if I do not label the agent information, the goods will be detained again during customs clearance, and if I label the information incorrectly, I will face fines later, and even affect the store's compliance rating. I want to ask: Is it required to include domestic agent information on imported food labels? What pitfalls should I avoid during labeling?

Expert Insights

Expert Q&A

Daniel Xu
Daniel XuYears of service:10Customer Rating:5.0

Director of Import & Export OperationsStart a Chat

First,we need to expose common industry misconceptions: many imported food practitioners mistakenly believe that only goods shipped directly from bonded warehouses need to label domestic agent information,or they can replace it with overseas suppliers,which is a typical compliance blind spot.

If domestic agent information is not labeled as required,it will trigger a chain of negative reactions: in the customs clearance process,the customs will judge the label as non-compliant,directly detain the goods and incur increasing daily detention and container detention fees. In severe cases,the goods will be required to be returned,even if you pass the customs by luck,if the supervision department finds the issue during random inspection after the goods enter the market,you will face removal of the goods,a fine of up to 50,000 yuan,and it will also affect the store's compliance rating,resulting in restricted access to platforms in the future.

Physical risk isolation measure: 10 days before the goods are shipped,submit the label design draft to a third-party institution with compliance qualifications or a professional foreign trade agency for pre-document review,and confirm that the labeling format and content of the agent information meet the requirements of national standard GB 7718.

Exclusive loss-mitigation tip: If the goods have been shipped and the labels do not meet the standards,you can immediately contact the compliance label revision agency at the port to apply for urgent rectification in the port area,and at the same time entrust an agent to submit a label rectification filing application to the customs,so as to shorten the detention time and reduce additional costs to the greatest extent.

Reference: Mastering Beer Import Customs: A 20-Year Expert Guide
Evelyn Li
Evelyn LiYears of service:3Customer Rating:5.0

Cross-border Compliance SupervisorStart a Chat

If the domestic agent information is not labeled on the imported pre-packaged food label, it will trigger a logical verification warning in the customs document review link, and directly transfer to the manual document review channel, and the customs clearance time will be extended by at least 3-5 working days. If the on-site inspection determines that there is a label compliance issue, the customs will issue a *Notice of Inspection and Quarantine Treatment* and require the enterprise to complete the label rectification and re-declare within the specified time limit.

If the enterprise fails to complete the rectification within 7 working days, the customs has the right to return or destroy the goods, and all resulting costs shall be borne by the enterprise itself. In addition, for enterprises that have accumulated 3 or more label compliance issues within 12 months, the customs will include them in the key supervision list, and all subsequent imported goods will be subject to 100% manual inspection, which will not only greatly increase the customs clearance cost, but also affect the enterprise's credit rating, resulting in restricted application of customs clearance facilitation measures in the future.

Cindy Chen
Cindy ChenYears of service:3Customer Rating:5.0

Key Account ManagerStart a Chat

If imported food is detained in the port due to the lack of domestic agent information, a series of chain costs will be incurred at the logistics end: the container detention fee at Yangshan Port is 120-180 yuan per TEU per day, and the detention fee is 3-5 yuan per cubic meter per day, and the fee will double if it exceeds 7 days. If you need to revise the label in the port area, you need to apply to the terminal for temporary operation space in advance. The label revision fee ranges from 50 to 200 yuan per box according to the cargo volume, and it will also occupy port operation resources, resulting in a longer label revision cycle.

In addition, if the original domestic delivery schedule is missed, it is necessary to re-coordinate trunk transportation and last-mile delivery resources, and may face liquidated damages from terminal channels. To avoid such problems, it is recommended to confirm the label compliance with the overseas supplier before the goods are shipped, reserve a 3-5 day customs clearance buffer period, and formulate a label revision and port transfer plan for abnormal situations.

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

The domestic agent information on imported food labels is not only a compliance requirement, but also directly related to tax declaration. As the responsible subject of imported food, the domestic agent needs to undertake the corresponding VAT and consumption tax declaration obligations. If the agent information is not labeled on the label, when the tax authority checks the input tax deduction vouchers for imported goods, it will reject the enterprise's input tax deduction application due to unclear responsible subject, resulting in the enterprise paying more taxes.

In addition, if the agent is involved in cross-border related-party transactions, the information on the label must be consistent with the related-party information filed for tax purposes, otherwise it will be judged as abnormal related-party transaction pricing, trigger tax investigation, and even face penalties for tax repayment and late payment fees. It is recommended that enterprises confirm that the information is fully matched with the tax filing materials before labeling the agent information, so as to avoid tax risks caused by inconsistent information.

Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

The domestic agent information on imported food labels must be consistent with the filing subject of cross-border receipts and payments, otherwise it will trigger a compliance warning from the State Administration of Foreign Exchange.

If an enterprise handles receipts and payments in the name of an overseas supplier but does not label the domestic agent on the label, the State Administration of Foreign Exchange will suspect false trade due to the mismatch between the transaction subject and the responsible subject, suspend the enterprise's receipts and payments authority, and require the enterprise to submit transaction authenticity certification materials, including purchase contracts, logistics documents, customs declarations, etc. In addition, if the enterprise uses RMB cross-border payment (CIPS system), the agent information on the label must be consistent with the domestic payer and payee information in the CIPS message, otherwise the payment message will be returned, affecting the payment settlement time. It is recommended that enterprises confirm that the label information is fully matched with the receipts and payments filing subject before handling receipts and payments.

Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

The domestic agent information on imported food labels is the core legal basis for defining product quality liability. According to the *Food Safety Law*, the domestic agent is the quality liability subject of imported food. If consumers have health problems due to eating imported food, they can directly claim compensation from the agent.

If the agent information is not labeled on the label, consumers cannot identify the responsible subject, and will directly claim compensation from the sales platform or the importing enterprise, and the enterprise needs to bear additional legal risks and compensation costs. In addition, if the procurement contract signed between the agent and the overseas supplier stipulates the label compliance obligation, the failure of the label to meet the standards will be deemed as a breach of contract by the supplier, and the enterprise can recover losses from the supplier according to the contract, but it is necessary to retain written evidence of label review and communication in advance to avoid difficulty in providing evidence.

Kevin Lin
Kevin LinYears of service:4Customer Rating:5.0

Trade Solutions ManagerStart a Chat

When the customs inspects imported food on site, the domestic agent information on the label is one of the core inspection items. The inspectors will check whether the agent's name, address and contact information are complete and accurate, and whether they are consistent with the information of the domestic consignee and consignor on the customs declaration form, in accordance with the *Administrative Provisions on the Review of Import and Export Food Labels*. If information missing or inconsistency is found, the inspection process will be suspended immediately, and the enterprise will be required to submit the qualification certificate of the agent.

If it cannot be submitted in time, the goods will be transferred to the supervised warehouse for processing. To deal with such situations, the enterprise needs to prepare copies of the agent's business license and food business license before the goods arrive at the port. The information labeled on the label must be fully consistent with the qualification documents, and at the same time submit the label sample to the inspection assistance agency for pre-review in advance to avoid being caught off guard by on-site rectification.

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

If the domestic agent information on imported food labels needs to be rectified later, it will involve secondary processing of packaging. If the packaging is made of fragile materials (such as color-printed iron cans, fragile glass bottles), problems such as packaging damage and blurred printing are prone to occur during label revision, resulting in the goods being unsalable. To avoid such situations, it is recommended to print the domestic agent information directly on the outer packaging during overseas production, rather than pasting it later.

If pasting is required later due to special circumstances, it is necessary to select label materials that are high-temperature and friction-resistant matching the packaging material, and the pasting position should avoid the seams and corners of the packaging to ensure that the label is firm and clear. In addition, during the label revision process, professional labeling equipment must be used to avoid problems such as offset and air bubbles in manual labeling, which will affect the compliance of the label.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

The compliance of the domestic agent information on imported food labels will directly affect the overall efficiency and cost of the supply chain. If the goods are detained in the port or the label is revised due to label issues, it will disrupt the original inventory turnover plan, resulting in stockouts at terminal channels and affecting brand reputation. From the perspective of supply chain planning, it is recommended that enterprises establish a "label compliance pre-check mechanism", incorporate agent information into the packaging design plan during overseas production, and sign binding clauses on label compliance with overseas suppliers to clarify liability for breach of contract and compensation standards.

At the same time, enterprises can use the global supply chain services of professional foreign trade agencies to outsource label review, document processing and other links, shorten supply chain response time and reduce compliance risks. In addition, enterprises can establish a label compliance database to record the label requirements of different categories of food, providing reference for subsequent import business.

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