As it relates to other food safety regulations in China, the authorities have classified foods like meat and dairy as "high risk" and infant formula as a food with "high consumer sensitivity," but it remains to be seen how GAC will define these categories under the new proposal. We expect the specific risk classification of different foods and more detailed implementation measures to be revealed and announced in 2020.
In addition, the Draft requires that the name and address of the manufacturer, as well as the registration number, shall be labeled on the minimum sales package of food exported to China. Notably, the validity period of the registration is proposed to be extended from the current four years to five years.
Keller and Heckman will continue to monitor the developments and assess how it may impact foreign companies exporting food to China. In the meantime, if you have any questions about this topic or would like more information about China food laws and regulations, please do not hesitate to contact David Ettinger (
[email protected]
), Jenny Li (
[email protected]
),
or your existing contact at Keller and Heckman LLP.
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