Exporting to China. The gate isn't the price, it is the registration.
In almost every market the negotiation starts with the product and ends with compliance. With China the order is reversed, and whoever doesn't know it loses months.
What you need, in one line: the facility registered in China, the four fixed shipping documents, the label in Chinese and the product category checked on the portal. The order matters: registration comes before everything else.
The facility must be registered before selling. The Chinese customs administration keeps a register of foreign facilities authorised to export food to China, searchable and managed through the CIFER system. Without the registration number, the goods don't get in.
From 1 June 2026 a new decree applies. Decree 280, issued on 14 October 2025, replaced Decree 248 of 2021 and redesigned the procedure, with registration valid for five years and renewable.
The requirements change by product category, and they change often. This page doesn't publish the list of categories, because a list like that goes stale within a few months: it is read on the portal, with your own category in hand.
This guide applies to food in general. For two products the path changes before the country does: wine travels with excise and its accompanying document, and olive oil has marketing and labelling standards all of its own. Whoever exports one of the two to China reads this guide and the product one.
This piece is part of the guide to export operations for the small food producer, and it is deliberately short. On a market that changes its own rules every few years, a long page is a page that will be wrong before it is read.
The template, to download
Fifteen rows in five stages, in this market's reversed order: before the negotiation, registration, before the shipment, the shipment, afterwards. Each row says where to check. At the bottom, four cells for the data to keep to hand: the category, the registration number and its expiry.
| File | What it contains | Link |
|---|---|---|
| ChinaExcel, one sheet | The five stages, the Status drop-down column, the source for each row and the four cells for category, number and expiry of the registration. |
The files are free. There is no form in front of them, we don't ask for an address and we receive no notification when someone downloads them. The sheet lists no categories, forms or rates, for the same reason this page is short: on this market a precise but old list does more harm than a pointer to the portal.
Why the order is reversed here
In most markets you can negotiate, agree a price and sort out compliance while the first shipment is being prepared. Not towards China: without the registered facility there is no shipment to prepare, and registration takes time that doesn't depend on you.
The commercial consequence is concrete. A Chinese buyer who asks you for a price is already taking it for granted that you are registered, and discovering the opposite at an advanced stage burns the credibility built up to that point. It pays to say so straight away, with the expected date.
What changed from 1 June 2026
Decree 280, issued on 14 October 2025 by the General Administration of Customs of China and in force since 1 June 2026, replaced Decree 248 of 2021. The most relevant change for a small producer concerns who submits the application and for which categories.
Under the previous regime the application always went through the competent authority of the exporting country. The new framework adds a registration by list alongside this route, described by the regulatory analysis we consulted in these terms: «the competent authority of that country (or region) may submit to the GACC a list of food manufacturers recommended for registration in China», provided the country's food safety system is recognised by the Chinese customs administration.
Registration, for businesses that meet the requirements set by the customs administration, is renewed automatically for another five years at the end of the validity period. The official list of categories subject to recommended registration is the element worth keeping an eye on, because it determines which of the two routes you have to take.
Where to look, in practice
| Step | Who does it | Where |
|---|---|---|
| Check the categoryfirst of all | You, with your product's code and description. It determines whether you need the Italian authority's recommendation or a direct application. |
The registration system for foreign enterprises exporting food to China, where categories and lists are consulted. |
| Register the facilitythe real gate | The business, with identity documentation, the declaration of conformity and, where required, the recommendation of the competent authority. |
In the same system, which issues the registration number to be shown on packs and documents. |
| Origin and dutiesno preference | You. The European Union has no free trade agreement with China, so there is no preferential origin and the buyer pays full duty. |
The document you need, if requested, is the Chamber of Commerce certificate of origin, not the EUR.1. Below €6,000 no preferential declaration makes sense, because there is no preference. |
The official portal is the registration system for foreign enterprises exporting food to China, available in Chinese and English. From there you consult the lists of facilities already registered and the product categories, and the application goes through it.
The two things to ask the buyer
First: the exact category in which your product is classified by Chinese customs. Second: whether they have already imported products in that category and from which facility. A buyer who answers both precisely is a buyer who knows what they are doing.
A buyer who can't answer isn't necessarily unreliable, but the negotiation changes nature: you are talking to someone who will have to learn alongside you, and the learning time must be factored in before promising a delivery date. On how to tell the difference, qualifying a foreign buyer.
Why this page isn't longer
Very detailed guides on China circulate, listing categories, forms and steps. The problem with those guides rarely lies in their quality. It lies in the fact that the subject changes, and a precise but old list does more harm than a short page that says where to look.
We checked the date and substance of the change of decree against regulatory sources that cover Chinese legislation, and we opened the official portal. We couldn't open the Chinese customs administration's website directly, and we state it here instead of pretending otherwise.
When the deadlines of a distant market get lost
A registration valid for five years looks like a problem solved for five years. In practice it is a deadline nobody watches for four years and eleven months, and it is discovered on the eve of an order, when reopening it takes time there isn't.
It is the kind of date that should be taken out of memory and put in a place that watches it on its own, with operational deadline alerts. With a constraint that matters more than the technology, written in Ethics: the system prepares and flags, but no document goes out without a person having read and approved it.
On this market the question that counts is just one, and it isn't price. If you write to us with your product, we look on the portal to see which category it falls into and whether your facility is already registered. It is a public check, we know how to do it, and we do it without asking you for anything.
A person replies, the same one who then builds the systems, within 24 hours, with a reading of the situation and not with a quote. You write from here, and one line is enough.
Questions and answers
What do you need to export food to China?
First of all, registration of the production facility with the Chinese customs administration, which keeps a register of authorised foreign facilities and manages it through the CIFER system. Without the registration number the goods don't get in.
It is the reverse of the usual order: in China compliance comes before the negotiation, not after. A Chinese buyer who asks for a price takes it for granted that you are already registered.
Is Decree 248 still in force?
No. Decree 280, issued on 14 October 2025, came into force on 1 June 2026 and replaced Decree 248 of 2021 on the registration of overseas manufacturers of imported food.
The new framework adds, alongside the application submitted through the competent authority of the exporting country, a registration by list, in which the country's authority submits a list of recommended facilities. Registration is valid for five years.
Who submits the registration application, me or my buyer?
Not the buyer. Registration concerns the production facility, so you, and goes through the CIFER system. Depending on the product category it may require the recommendation of the competent Italian authority.
That is why the first question to ask the buyer concerns the exact category in which the product is classified by Chinese customs: which route you have to take depends on that answer.
Do you need the EUR.1 to export to China?
No, and it would serve no purpose. The European Union has no free trade agreement with China, so there is no preferential origin to prove and the buyer pays full duty.
The origin document that may be requested is the certificate of origin issued by the Chamber of Commerce, which attests the «made in» and gives no right to any reduction. The distinction between the two documents is explained on the dedicated page.
How long does registration last and does it have to be renewed?
Registration is valid for five years. For businesses that meet the requirements set by the Chinese customs administration, at expiry it is renewed automatically for another five years.
The practical risk isn't the renewal itself, it is that a five-year deadline isn't watched by anyone until it is imminent, and at that point reopening it takes time a negotiation under way doesn't have.
Notes on sources
- Registration system for foreign enterprises exporting food to China (CIFER), official portal in Chinese and English, opened and checked on 6 September 2026. From here you consult the list of facilities already registered and the product categories.
- For the date and content of Decree 280 (issued on 14 October 2025, in force from 1 June 2026, replacing Decree 248, registration by list, five-year validity) we used CIRS Group's regulatory analysis, confirmed by a second independent source. The Chinese customs administration's website didn't open for our tools and we state it: we haven't read the primary source.
- This page doesn't publish the list of product categories subject to recommended registration, nor forms, nor duty rates. On a market that has rewritten its own rules twice in five years, a precise but old list does more harm than a pointer to the portal.
On China the right question comes before the price.
What the category is, and whether the facility is registered: two questions that shift a negotiation by months. With Itria we start from the outside to build custom digital systems for exporters. For you that translates into more requests, fewer losses and less manual work. Write us a line about what weighs on you. We take the first step: what a buyer sees when they look you up, and what we found there. Even if we don't end up working together.