1. Definition

Feed is a product made with industrialized processed ingredient(s) for animals, including single feed, premixed feed, concentrate, compound and supplementary feed. (Including pet food)

Feed additive is a substance added to feed during the processing, formulation and use in a small or minimum volume, including nutritional feed additives and common feed additives. (Including pet food)

2. Relevant Authorities

Ministry of Agriculture and Rural Affairs – formulating regulations and standards, issuing import registration certificate.

General Administration of Customs (GAC)—market access approval, customs inspection and quarantine

State Administration for market regulation—market supervision of domestic and imported feed products.

3. Relevant regulations

On Apr. 27, 2018, several regulatory documents were issued in accordance with the No.20 Announcement of China Ministry of Agriculture and Rural Affairs. According to this announcement, pet food now is separately regulated from feed products, and here are their corresponding regulations:

Item

Feed

Pet feed

Management requirements

Regulations on the Administration of Feeds and Feed Additives

Administrative Measures for Pet Foods in China

Hygiene requirements

GB 13078-2017 Hygiene Standards for Feeds (effective on May 1, 2018, explicitly excluding the pet feed)

Provisions on Hygiene of Pet Foods in China

Labeling requirements

GB 10648-2013 Feed Label

Provisions on the Labeling of Pet Foods in China

Product standards

GB/T 5915-2008 Formula Feeds for Piglet and Growing-finishing Pigs

GB/T 5916-2008 Formula Feeds for Replacement Pullets, Laying Hen and Broilers

GB/T 22919.1-2008 Aquafeed-Part 1: Formula Feed for Penaeus Monodon

……

GB/T 31216-2014 Complete Pet Food - Dog Food

GB/T 31217-2014 Complete Pet Food - Cat Food

GB/T 23185-2008 Pet Food - Dog Chews

……

Feedstuff requirements

Catalog of Feedstuffs (including the supplementary notice)

GB/T 19541-2017 Feedstuffs-Soyabean

NY/T 2218-2012 Feedstuffs-Fermented Soyabean

……

Additive requirements

Catalog of Feed Additives (including the supplementary notice)

Regulations on the Safety Use of Feed Additives

GB 9840-2017 Feed additive - Vitamin D3 (Beadlets)

GB 9454-2017 Feed Additive DL-α-Tocopheryl Acetate

……

Drug

Regulations on the Use of Feed Drug Additives

Banned substances

1. Any substances forbidden to be added to the feeds and drinking water for the animals.

2. Any veterinary drugs and other compounds forbidden to be administered by the food animals.

Import registration certificate

Administrative Measures for the Management of Imported Feeds and Feed Additives

Administrative Measures for the Inspection and Quarantine Management of Imported Feeds and Feed Additives

4. Regulatory requirements

4.1 Feed products

Ingredients

“Regulations on the Administration of Feeds and Feed Additives” stipulates that only feed ingredient listed in directory of feed raw materials, directory of feed additives and directory of medical feed additive can be used in feed products. The positive list for feed raw material and feed additives were all updated in 2018.

• China Approved Feed Additives (update on 2018.5.16)

• Revision to the “Catalogue of Feed Raw Materials” (Issued on 2018.4.27)

Label

The mandatory labeling items of feed product includes:

• Words that “this product conforms to feed hygiene standard”

• Product name

• Guaranteed analytical value of product

• Ingredient component

• Product standard number

• Instructions

• Net content

• Manufacture date

• Shelf life

• Storage condition

• Name and address of manufacturer and operator

• Others

Notes:

• For imported products, origin country/region shall be indicated in Chinese

• Any content concerning animal disease prevention or treatment is prohibited for feed products, except for feed contained drug feed additives.

4.2 Pet food

Interpretation on China New Pet Food Regulations

5. Market access

Following 3 sections are the key points of overseas feed products entering into Chinese market:

Approval at country level

China will carry out risk assessment of the export country/region to see whether this country is capable of guaranteeing the product safety. There is a directory specifying the approved countries and corresponding feed product category, and only products conforming to the list are allowed to be exported to China. This is the fundamental requirement for the import of feed products, and currently 17 countries/regions are allowed to export pet food products to China, which are:

Thailand, Taiwan, Philippines, Uzbekistan, Netherlands, France, Belgium, Germany, Denmark, Czech Republic, Italy, USA, Canada, Brazil, Argentina, New Zealand and Australia.

Enterprise registration

The overseas feed manufacturers should be registered with China GAC if they intend to export products to China. First of all the enterprises need to submit their application at a national level to their relevant authority, who will recommend qualified enterprise to China. After sampling inspection by GAC, those compliant enterprises (including enterprises not be sampled) will be granted registration approval. The enterprise registration remains valid for 5 years, and an application for renewal should sent to GAC 6 months prior to expiration.

Import registration certificate

When the overseas enterprise exports feed or feed additives to China for the first time, it must apply for the import registration certificate to Ministry of Agriculture and Rural Affairs and must also be granted product registration approval. The certificate remains valid for 5 years and renewal should be applied 6 months prior to expiration.

5 Step Guide for Feed & Additive (Incl. Pet Food) Import Registration Certificate

1. Prepare the pre-market application dossier & labelling

A pre-market application dossier & materials must be compiled for each imported feed & additive (Incl. Pet food) product and then submitted to China Ministry of Agriculture and Rural Affairs for quality and safety evaluation. The application materials required include: Chinese labelling, quality standards, test & production methods and test reports and others.

2. Appoint Agent

A fundamental requirement for import registration license is the appointment of a qualified Chinese legal entity/POA to represent your company during the application procedure.

3. Submit application form & materials to Ministry of Agriculture and Rural Affairs

The Ministry of Agriculture and Rural Affairs will review the application materials within 10 working days. If the application documents meet the requirements, the department will notify the applicant to send samples to the designated testing laboratories for verification testing.

4. Verification Testing

The verification testing of product quality is composed of a quality standard review and testing of the samples. The verification testing should be completed within three months. For new feed & additives additional testing would be required.

5. Import Registration License

If the verification test results meet the requirements, Ministry of Agriculture and Rural Affairs shall issue the registered license for import feed and feed additive within 10 working days and make it public.