01 Correctly understand the concept of fist import

According to Article 11 of the Measures for the Supervision and Administration of Inspection and Quarantine of Imported and Exported Dairy Products, first import refers to the first import of dairy products with exactly the same information such as overseas production enterprises, product names, formulas, overseas exporters, and domestic importers from the same port. It can be seen from the regulation that if the above 7 information of a certain batch of imported dairy products is not completely consistent with the previous imports, the batch of dairy products belongs to first import. Among these 7 information, the one that needs special attention is "overseas exporter".

7 information: overseas production enterprises, product name, formula, overseas exporter, domestic importer, same port, first import.

02 Correctly understand the requirements of "corresponding national food safety standards"

According to Article 11 (3) of the Measures for the Supervision and Administration of Inspection and Quarantine of Imported and Exported Dairy Products, "for the first imported dairy products, the test report of items listed in the corresponding national food safety standards shall be provided." What does "corresponding national food safety standards" mean?

The corresponding national food safety standards include not only the national standards of the product itself, but also other national food safety standards quoted by product standards.

For example, the national standard for milk powder is GB 19644. The Article 4.4 of the standard stipulates: contaminants should meet the provisions of GB 2762, Article 4.5: mycotoxin limit should meet the provisions of GB 2761, and Article 4.7.2 stipulates: the use of food additives and nutritional fortification substances should meet the provisions of GB 2760 and GB 14880. Therefore, the "corresponding national food safety standards" for the first imported milk powder refer to GB 19644, GB 2762, GB 2761, GB 2760, and GB 14880.

03 Ensure that corresponding national food safety standards are currently valid

In order to fully protect the health rights of people and take into account the development needs of food industry, the national food safety standards will be revised from time to time. For example, the National Health Commission revised GB 2762-2017 National Food Safety Standard Maximum Levels of Contaminant in Foods on February 22, 2021, and formulated GB 10766-2021 National Food Safety Standard Older Infants Formula (implemented on February 22, 2023) to replace the contents of formula food for 6-12 months old of older infants in GB 10767-2010 National Food Safety Standard Older Infants and Young Children Formulas. Therefore, importers should ensure that the national food safety standards they are based on are currently valid.

Importers can query the currently valid national standards through the data retrieval platform for national food safety standards (https://sppt.cfsa.net.cn:8086/db).

04 Ensure that test items cover the items specified in corresponding national standards, and test results should meet the provisions of national standards

Taking milk powder as an example, the test report attached for first import includes not only the physical and chemical indicators and microbiological items in GB 19644, the contaminant items in GB 2762 and the test results of mycotoxins in GB 2761, but also the test results of food additives and nutritional fortification substances in ingredients list.

All test results shall not exceed the limit specified in the standard.

Source: 12360 Customs Hotline

Note: This article is compiled by Antion, please indicate our source if reprint it.