Regulatory Compliance Service on Imported Food Contact Materials and Articles

1. Regulation background

Food Contact Materials (FCMs) are defined as the materials and articles intended to come into direct or indirect contact with food (e.g. equipment, containers, packaging and various utensils etc.), therefore, the constituents of FCM may transfer into foods, which may be harmful to consumer health and safety. General Administration of Quality Supervision (AQSIQ) pays high attention to inspection and supervision of imported FCM. The inspection and quarantine department carry out inspection and management for FCM according to“Law of the People's Republic of China on Import and Export Commodity Inspection”and its enforcement regulation,“Supervising Standard for Food Contact Material Import and Export”as well as the relevant product standards.

2. Compliance procedure for imported FCM

Depend on in-depth study of framework regulation and product standard as well as good communication with relevant department and Long-term practice, CIRS have successfully assist client import FCM and its articles to China. To tackle with the trade barrier and avoid compliance risk, CIRS have developed one set of compliance procedures:

3. Our services

3.1 Confirm standard

To import FCM to China, definite standard is necessary, if rashly import FCM which be without definite standard may cause rejection or destroyed by local inspection and quarantine bureau. To avoid trade loss, CIRS suggests that client should confirm the corresponding product standard before importing. CIRS provides:

1.     Product analysis, ensure the product material

2.     Confirm the product corresponding standard; communicate with the authority if necessary

3.     For the product which does not have corresponding standard, we can provide similar applicable standard.

4.     For the new type product or new material, we can communicate with the authority and provide the final solution.

3.2 Raw material check

In China FCM additives have an explicit positive list (GB 9685), the substance which is not included could not use asFCM additives, in addition there are also requirements for the raw materials. CIRS suggest that the importer should check the raw material and additives according to Chinese regulation. CIRS provide:

1.     Product analysis, check the compliance of material and its additives.

2.     Ensure the limit of the restricted substance according to the relevant regulation.

3.     Arrange necessary tests (including SML, QM tests)

4.     Issue the Document of Compliance (DoC).

5.     New food contact substance notification

3.3 Pre-testing

The importer provides the representative samples to the qualified laboratory for pre-testing. The laboratory tests the sample according to national standard and issue the testing report.

CIRS will arrange the testing to qualification laboratory and follow up the testing schedule. For further information, please click Food Contact Material Testing

3.4 Label

According to the statistics of the “2015 Import Food Contact Material White Book”, 7751 batches of FCM product were rejected because of unqualified label, which is far above any other reasons for rejection, becoming the most crucial issue for the trade frictions of FCM.CIRS provides:

1.     Manufacture the compliance label for FCM

2.     Review the original and Chinese label of FCM

3.5 Custom clearance

According to the stipulation of “Supervising Standard for Food Contact Material Import and Export”,China Custom and Bureau of Quality Supervision will carry out testing for each batch of FCM, except basic trade documents, conformity documents and product specification is necessary. The Custom testing center or authorized agency will issue the inspection report within 15 days after receive the sample, CIRS will provide:

1.     Design the import proposal for specific product, streamline the custom clearance procedure.

2.     Stand for client to Communicate with the authority for the controversial product

3.6 Registration for import FCM

In China, register system implemented in import FCM product supervision. The register is not mandatory yet, however, as the FCM is attaching more and more attention, relevant regulations improve steadily, the regulatory agency recommend that the importer would better register for their FCM products.The registration is of great advantage to shorten the time when you go through the Custom as well as reduce the risk of rejection. CIRS will assist the importer to transact the registration:

1.     Submit the application form to the local CIQ on site

2.     Contact with CIQ laboratory for necessary testing

3.     Prepare the application dossier and communicate with relevant department until getting the registration notification

No.

Requirement documents

1.

Import Food contact material application form 

2.

Copies of the license of the business corporation of the registration applicant

3.

The food contact material product conformity documents

4.

The product material specification

5.

The product brand, model, producing area, photo, label, specification, etc.

6.

The product material testing report which is issued by the CIQ laboratory

Application process

3.7 Regulation consulting service

With the promulgation of new Food Safety Law in China, the concerns of legislation and supervision for food related products have reached a new height. The corresponding standards are being completed actively. In the near future the new standards will come out successively, stakeholders should concern the regulation updating closely, to avoid the loss which cause by incompliance. CIRS can provide:

1.     The regulation updating and relevant information timely

2.     The translation version of updating regulation  

If you have any question, please contact us at Service@cirs-reach.com without any hesitation.