Five reasons that imported British food fails Chinese customs inspections

There are a number of reasons why British foods don’t make it past Chinese customs, Yilia Ye of ChemLinked explains the most common mistakes

According to China’s Ministry of Commerce, China has become Britain’s 6^th most important trade partner with food & beverage exports amounting to £330 million in 2018. Hindering further growth are the risks associated with market access in China, specifically the possibility of Chinese customs rejecting consignments of British goods.

In general, customs officials reject consignments on two major criteria: deviations from Chinese national standards and food safety/hygiene issues. With reference to Chinese customs data, approximately 423 batches of food products exported from the UK were rejected from 2015 to 2018, with beverages, pastry and biscuits and candy and chocolates being the top three categories of British food rejected.

ChemLinked summarised the top 5 reasons for import failure below:

1. Exceeding shelf life

In 2017, 209 batches of British food products were rejected due to violations of shelf-life requirements, accounting for 70 percent of all batches of British food rejected that year. The obvious logistical challenges of transporting perishable goods from Britain to China are further compounded by the time necessary to complete customs and quarantine inspection at Chinese ports, which in the past has taken an average of 20 days.

In this respect, there have been several extremely positive developments for British exporters. Policy reforms affecting administrative processing of consignments of goods will greatly improve the situation and should lead to greatly expedited customs clearance times. Customs officials have already implemented a series of trade facilitation measures that include simplified documentation requirements and integrating customs declaration and inspection. Under the new policy environment, it is possible for certain foods to receive customs clearance in just three days.

2.Lack of required documents or evidentiary materials

High risk food products such as meats and seafood, as well as special foods (infant formula, health foods, etc.), must obtain market access approval prior to importation, with the enterprise submitting a full test report based on the items listed in national food safety standards. With imported dairy for instance, a quarantine permit is mandatory for raw milk, raw milk product and pasteurized milk. ChemLinked strongly advises stakeholders to have a firm understanding of all market access obligations prior to exportation and to prepare all required documents in advance.

Customs officials reject consignments on two major criteria: deviations from Chinese national standards and food safety/hygiene issues

3. Products fail to meet Chinese national food safety standards

China’s regulatory framework for foods and beverages is a complicated system of horizontal standards that specify rules for all foods, including labeling, use of food additives, nutrient fortification requirements, etc. In addition, there are vertical standards which specify the individualized product specific requirements for various categories of foods. Deviation from these standards is another major headache for British exporters and another common reason for goods being rejected by Chinese officials during customs inspections.

In recent years, China’s regulatory framework has undergone a period of rapid change as it struggles to keep pace with China’s evolving socioeconomic environment. For exporters, staying abreast of these changes can be a daunting prospect and in certain sectors confers considerable risks to investment; the almost cyclical changes in regulation of China’s infant formula sector is a particularly difficult area. Recently China has again proposed revisions to national food safety standards for dairy products, cheese, and infant formula food.

4. Improper use of food additives/nutritional fortification substances

Improper use of food additives/nutritional fortification substances is another significant contributor to Chinese customs rejecting consignments of British foods. Even large multinationals like Nestle suffer in this regard. Importantly, mistakes in this area have the potential of impacting subsequent consignments as China implements a blacklisting system whereby compliance violations are recorded, and the stringency of future inspections stratified are based on the track record of the importer. Importers with a history of violations are subject to more stringent customs inspections. GB 2760 (food additive standard) and GB 14880 (nutrient fortification standard) lists permitted food additives/nutritional fortification substance and stipulates their usage requirements in China. The standards are long and complicated and correctly interpreting compliance requirements can be difficult.

5. Labelling non-compliance

From 2015 to 2018, approximately 5.7 percent of British food exports violated Chinese labelling regulations with tea, beer and biscuits most significantly impacted. As part of the trade facilitation measures previously mentioned, label filing for prepackaged imported food will no longer be required from 1^st October 2019. It will be regarded as a normal sampling inspection item during customs release and the importer shall bear the major responsibility of the label issue.