GACC Decree 280 took effect on 1 June 2026. Under the rules, food entering China through cross-border e-commerce — whether 9610 direct mail or 1210 bonded stock — does not currently require overseas manufacturer registration.
Many people stop reading there. Our advice to clients is the opposite: register anyway.
1. Why register when it is not required
- One standard, no double standard. The same food needs registration via general trade but not via cross-border e-commerce. That is legally correct, but to the person eating it, it is the same product. Set your own floor; do not let the shipping method decide how high your safety bar is
- No restart when you switch routes. The most common story: test the market through cross-border e-commerce, sales take off, you move to general trade to cut unit cost — and only then discover the factory is not registered. That can mean months of waiting, longer still for the 17 categories that need a recommendation from the home-country authority
- The exemption has limits. The cross-border e-commerce facilitation does not cover goods from areas under an import suspension, or goods with a major quality or safety risk. If something goes wrong, a registered manufacturer with a record is in a far stronger position
- Platforms and ports ask anyway. Some platforms and onshore service providers ask for manufacturer credentials at listing; for sensitive categories such as health food, inspections and document checks through Hong Kong have kept tightening
This is our judgement, not a legal requirement. The regulation is the floor; a business that intends to last sets its own standard above the floor.
2. The rules, in one table
| Regulation | Provisions of the PRC Customs on Registration of Overseas Manufacturers of Imported Food (GACC Decree No. 280), in force from 1 June 2026, replacing Decree No. 248. Already-registered manufacturers are unaffected |
|---|---|
| Who registers | Overseas manufacturers, processors and storage facilities exporting food to China — the factory and cold store, not the trader. Traders or brand owners can act as agent and apply on their behalf. Food additive and food-contact product makers are out of scope |
| How | 17 higher-risk categories need a recommendation from the home country or region's competent authority; everything else can apply to GACC directly or through an agent |
| Validity | 5 years, renewed automatically on expiry (except categories on the no-automatic-renewal list, such as meat products and edible bird's nest products) |
| Packaging | Must show the China registration number, or the registration number approved by the home-country authority |
| Cross-border e-commerce | Decree 280, Article 30: retail cross-border e-commerce food imports are handled "in accordance with relevant provisions". Under Shang Cai Fa [2018] No. 486, both 9610 direct purchase and 1210 bonded online purchase are supervised as personal-use goods, without first-import licence, registration or filing requirements |
| Official guide | GACC service guide · overseas food manufacturer registration (Chinese) |
The 17 categories that need an official recommendation: meat and meat products, casings, edible bird's nest and products, bee products, eggs and egg products, edible oils and fats, stuffed pasta and dumplings, edible grains, milled grain products and malt, dehydrated vegetables, seasoning powders, nuts and seeds, dried fruit, foods for special dietary uses, health food, dairy and aquatic products.
3. "Supervised as personal goods" is not the same as personal post
These two get mixed up all the time. Cross-border e-commerce being "supervised as personal-use goods" does not make it personal post. They are separate routes:
- Personal post: genuinely private parcels, capped at RMB 800 per shipment from Hong Kong, Macau and Taiwan, taxed at postal rates (see the RMB 800 limit on parcels into mainland China)
- Cross-border e-commerce: retail sales through a platform, up to RMB 5,000 per order and RMB 26,000 per person per year; customs duty is currently 0%, and import VAT and consumption tax are charged at 70% of the statutory amount, collected order by order
Neither requires manufacturer registration. The route that does is general trade, where food is declared as cargo.
4. Three routes, and how we choose
| General trade | The whole consignment is declared on import and shipped from a mainland warehouse. Cheapest freight and fastest delivery, but you need a qualified mainland consignee to declare, and duties and VAT are paid up front. Our view: once sales are steady, or for distribution and domestic e-commerce, this is where most products should end up |
|---|---|
| 9610 direct mail | Stock stays in Hong Kong; each order ships as an individual parcel. Tax is paid per order, with no upfront duty on the whole batch, but international freight is per parcel, so it costs more, and every sale has to be picked, packed and labelled in Hong Kong. Our view: for new brands, many SKUs in small volumes, and proving demand |
| 1210 bonded | Stock goes into a special customs supervision zone in the mainland (such as a comprehensive bonded zone); tax is paid per order when goods leave the zone, and delivery is fast. It only runs in approved cities, needs bonded warehouse arrangements, ties up a batch of stock, and does not allow "bonded plus offline pick-up" outside the zone. Our view: once cross-border e-commerce sales are proven and you want shorter delivery times |
Both cross-border e-commerce routes need an onshore agent — a company registered in mainland China — to register with customs on your behalf and carry joint liability. Your own mainland company can take this role. Products must also be on the positive list of retail cross-border e-commerce imports.
5. How we help
| 9610 direct mail | Stock sits in our Tsuen Wan warehouse; when orders come in we pick, pack and apply courier labels — the most tedious part of 9610, done for you in Hong Kong |
|---|---|
| General trade | Dedicated Fujian–Hong Kong "one lock" cross-border trucks, T+2 to Xiamen, cleared in Xiamen and forwarded anywhere in China. No mainland consignee? Our mainland company can act as consignee under a separate entrustment |
| Documents | Product name, HS code, net and gross weight, packages, trade terms and more, prepared to China Customs declaration standard fields in one go |
Every food and every origin is different. Rather than guess, come and sit down with us at our ground-floor shop in Kar Lee Industrial Centre, Tsuen Wan.
Address: Shop 1, G/F, Block B, Kar Lee Industrial Centre, 5-21 Pak Tin Par Street, Tsuen Wan, New Territories, Hong Kong · Tel +852 2542 4466.
Want to sell food into China but not sure which route?
Tell us the product, origin, whether the factory has a China registration number, rough monthly volume, and whether you have a mainland consignee. We will tell you whether general trade, 9610 or 1210 fits — including what we cannot do.
Book a meeting on WhatsApp FG Super App Hong Kong to China rates WeChat support Call +852 2542 4466Frequently asked questions
Does food sold via cross-border e-commerce need China manufacturer registration?
Not at present. Article 30 of GACC Decree 280 says retail cross-border e-commerce food imports follow the relevant provisions, and under Shang Cai Fa [2018] No. 486 both 9610 direct purchase and 1210 bonded imports are supervised as personal-use goods without registration or filing requirements. Forever Gain still recommends registering, using the general-trade standard as your food safety benchmark so you never have to restart when switching routes.
Is there any difference between 1210 bonded and 9610 direct mail on registration?
No. Both are retail cross-border e-commerce imports and neither currently requires registration. The difference is operational: 1210 stock sits in a mainland special customs supervision zone and tax is paid per order on release; 9610 stock stays in Hong Kong and each order ships as a parcel.
If cross-border e-commerce is supervised as personal goods, is it the same as personal post?
No. Personal post covers private parcels, capped at RMB 800 per shipment from Hong Kong, Macau and Taiwan and taxed at postal rates. Cross-border e-commerce covers platform retail sales up to RMB 5,000 per order and RMB 26,000 per person per year, with 0% customs duty and import VAT and consumption tax at 70% of the statutory amount. Neither requires manufacturer registration; general trade does.
What changed from Decree 248 to Decree 280?
Decree 280 took effect on 1 June 2026 and replaced Decree 248. Registered manufacturers are unaffected; the new rules simplify how new applications are made and what they need, and registration lasts 5 years with automatic renewal, except for categories on the no-automatic-renewal list.
Which foods need a recommendation from the home-country authority?
17 categories: meat and meat products, casings, edible bird's nest and products, bee products, eggs and egg products, edible oils and fats, stuffed pasta and dumplings, edible grains, milled grain products and malt, dehydrated vegetables, seasoning powders, nuts and seeds, dried fruit, foods for special dietary uses, health food, dairy and aquatic products. Other foods can apply to GACC directly or through an agent.
Can a trading company register in its own name?
No. Registration is for overseas manufacturers, processors and storage facilities — the factory and cold store. A trader or brand owner can act as agent and submit the application to GACC on the factory's behalf.