Animal feed and pet food products must be registered with China’s Ministry of Agriculture and Rural Affairs (MARA), formerly the Ministry of Agriculture (MOA), before they can be circulated in the Chinese market. Please note that many of MARA’s websites still say “Ministry of Agriculture” or “MOA.”
Companies should check MARA’s Feed Ingredient Catalogue, or Feed Additive Catalogue to ensure that the product they wish to export to China is listed. These are mostly generic feed product types. If your feed product appears in these catalogues, the product may not need to be registered; however, it is always best to check with your importer on this. The products in these catalogues are considered “traditionally traded,” and most standard feed products are listed. New feed types or proprietary feeds will need to be registered with MARA and added to the respective catalogue. (The Foreign Agricultural Service’s GAIN report #15062 (pdf) also contains useful information on this topic.
In addition, overseas manufacturing facilities (other than the product developer or company that originally applied for the product registration) wishing to export these products to China are required to apply for an import registration license with MARA.
It is recommended that companies work through a subsidiary in China, or hire a Chinese agent to provide registration services. The China-based agents have experience registering foreign products, and have the paperwork/application/etc. needed for submission of the registration applications. Most of MARA’s documents and websites are in Chinese, and some of the registration material must be submitted in Chinese. Companies should exercise caution in choosing an agent, as there are fraudulent companies offering this type of service. Please check with your importer or industry group for information on these agencies.
Product registration application materials may found on MARA’s website.
Dossier Preparation and Submission
MARA requires the following documents:
- An application form to register imported feed or feed additives
- A letter of delegation and a qualification certificate of the representative agent: if an overseas enterprise has a representative office established in China, then an original letter of delegation and a copy of the representative office registration license should be provided; if an overseas enterprise uses a local agent in China, an original letter of delegation and a copy of the corporate business license of the agent should be provided.
- Approval certificate for production and use issued by the country of origin, registration documents issued by country or regions outside of the country of origin (if applicable), and information on the product promotion and use. State-level certificates are usually acceptable.
- Name of imported feed product, composition, physical and chemical features, application scope, and instructions for use; name of imported feed additive, main composition, physical and chemical features, product origin, purpose of use, scope of usage, and use methodology.
- Processing technology, quality standard, test methodology and test report.
- Original label at manufacturing, trademark, and sample label in Chinese.
- For micro-bioorganisms or fermented products, the bacteria strain number issued by the competent authority should also be provided.
A product sample may also be required.
Recently-added traditionally-traded feed additive products are currently listed on the following GACC websites:
- List of registered facilities and products for feed additives and feed with pre-mixed feed additives that are allowed to be imported into China. This spreadsheet includes all origins and then by company. Per the U.S.-China Agreement, the list includes 13 of the recently-added traditionally-traded products.
- List of registered overseas facilities for natural mineral-based feed products. On this website you must select the U.S. list, which is the 8th link. This list includes one new product (per the Agreement).
- List of registered overseas facilities for compound feed products. On this website, you must select the U.S. list, which is the 3rd link. This list includes 9 new products (per the Agreement).
DDGS Product/Facility Registration*
All plants producing DDGS must obtain a certificate (Registration Certificate) from MARA showing they are registered and approved by MARA to export to China. The product and facility registration are done as a single registration with one application. Once this process is completed, the facility can be added to the list on GACC’s website. (The link on the page opens an Excel spreadsheet with several different facility lists. Select the tab at the bottom of the spreadsheet with the number “88” in the title – this is the DDGS facility list.) The registration is valid for 5 years.
Dossier Preparation and Submission
MARA requires the following documents to be included in the submission, and that all English documents to be translated into Chinese (Chinese names of the content should be consistent with the National Standard for DDGS):
- Application form
- Domestic Agent’s business license (if using a Chinese agent)
- Power of attorney (authorization letter) to authorize your agent in China to perform the registration for your company’s behalf
- Free Sales Certificate (original) and Feed Manufacturing License (normally issued by state departments of agriculture), notarized by the Chinese embassy or consulate in the U.S.
- Material Safety Data Sheet (MSDS) for the DDGS product - physical and chemical specifications
- Product of origin statement and product composition
- GMO safety certificate (This certificate is issued by MARA. If you have already exported DDGS to China, your trader in the U.S. or China should already have this certificate)
- Production process description and flow chart
- Product quality standards – of the manufacturing facility, should meet Chinese national standard per regulation GB/T 1.1-2009. This document should contain the specifications of the final product; i.e., appearance, nutrient analysis, hygiene index (such as Salmonella/ Aflatoxin B1/Mold count, heavy metals, etc.)
- Label (in English - mock up or sample or picture of a label used in the U.S)
- Product description (purpose of usage, application scope in different animal feed, package material and product weight per package, shelf life, storage conditions)
- Registration Certificates in other countries (if applicable)
- Reference dossier/documents – should include:
- the official definition of DDGS from the Association of American Feed Control Officials (AAFCO),
- guidelines for DDGS usage in feed from the American Feed Industry Association,
- MSDS of yeast product used in the fermentation process, and
- a document explaining the relationship between the yeast supplier and DDGS producer (if it is only a business relationship, just state that).
New registrants or companies needing to revise facility information – please notify USDA’s Agricultural Marketing Service (AMS) that you have received a license to export to China, or need to make a revision to current facility information, at the following address: EV.Export@usda.gov.
Animal feed and pet food production facilities must be registered with China’s General Administration of Customs (GACC) in order to be able to export to China. GACC maintains lists of registered facilities, and a facility must appear on GACC’s list before it can export to China. Per the U.S.-China Agreement, GACC has a maximum of 20 working days to update its facility lists after receiving updates from the U.S. Please note that while there is no agreed-upon timeframe for the U.S. to provide these updates to China, the updates will likely be provided on a monthly basis.
There are different types of facility registrations depending on the commodity being exported to China. Companies exporting to China need to work with the U.S. regulatory agency identified below to submit appropriate information on facility registration prior to exporting a product that has been registered by MARA.
- Forage & Plant Product Facilities: (non-DDG products) (Alfalfa hay, Alfalfa cubes & pellets, almond meal cubes & pellets, Timothy hay, beet pellets)
- APHIS’ Plant Protection and Quarantine handles facility registration for forage and plant-based feeds, and is currently working on market access for alfalfa cubes & pellets, almond meal cubes & pellets, and Timothy hay. Please contact your local APHIS field office for more information.
- View China’s list of approved facilities
- Pet Food and Animal-based Feed Product Facilities:
- APHIS’ Veterinary Services (VS) is handling facility registration for pet food and animal-based feeds. All facilities must be inspected by VS to be eligible for inclusion on GACC’s list. Please contact your local VS Service Center for more information (pdf).
- Information on China’s requirements for pet food and animal-based feed products.
- View China’s list of approved pet food facilities.
- View China’s list of approved animal-based feed facilities
- Feed Additives, Premixes, and Compound Feed Facilities:
- Please follow the steps listed on FDA’s website
[*Thanks to the U.S. Grains Council for providing extensive information on DDGS registration.]