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Double Changes of GACC Registration Process for Overseas Imported Meat Factories and the New National Standard Effective in September

The imported meat industry is currently facing two major policy changes. First, the General Administration of Customs of the People's Republic of China (GACC) Order No. 280 has been officially implemented on June 1, 2026. Second, GB 2762-2025 National Food Safety Standard - Maximum Levels of Contaminants in Food will take effect on September 2, 2026, bringing fundamental changes to the heavy metal judgment rules for dried meat products. The superposition of the two policies will lead to return risks for importers who fail to make adequate preparations.

This article comprehensively clarifies the two major policy updates.

Part 1: GACC Registration Process for Overseas Production Enterprises of Imported Meat

1. Pre-judgment: Registration Mandatory for Meat Products

All overseas production, processing and storage enterprises exporting food to China are required to complete GACC registration in accordance with GACC Order No. 280. No exemption is available for meat products.

2. Pre-judgment: Official Recommendation Required for Meat Registration

Meat and meat products fall into the category of official-recommended registration. In accordance with GACC Announcement No. 27 of 2026, the catalog of food products requiring official recommendation for registration covers 17 categories, with meat and meat products ranking first, followed by casings, bird’s nest and bird’s nest products, bee products, eggs and egg products, edible oils and fats, stuffed pasta, edible grains, grain flour and malt, dehydrated vegetables, powder condiments, nuts and seeds, dried fruits, special dietary foods, health food, and dairy products.

3. Required Registration Documents

(1) Enterprise registration application information: enterprise name, country/region of origin, production site address, legal representative, contact person and contact information, registration number approved by the competent authority of the home country, types of food applied for registration, etc.

(2) Enterprise identity documents: business license or certification documents issued by the competent authority of the home country

(3) Enterprise statement: a letter of commitment complying with GACC registration requirements

(4) Inspection report and recommendation letter: inspection report and official recommendation letter issued by the competent authority of the home country

Note: All application documents shall be in Chinese or English. GACC may additionally require production and processing procedures, product photos, factory floor plans, HACCP/ISO certification certificates and other food safety system compliance documents when necessary.

4. Application Submission

Applications shall be submitted via the China Import Food Overseas Manufacturer Registration System (CIFER).

5. GACC Review and Assessment

GACC conducts comprehensive assessment and review through written verification, video inspection, on-site inspection or a combination of the above methods.

6. Acquisition of Registration Number

Enterprises that meet all compliance requirements will be registered and issued a unique China-bound registration number with an official written notification. The registration is valid for 5 years.

⚠️ Special Notes for Meat Enterprises

(1) No automatic renewal: Meat products are included in the list of products excluded from automatic registration renewal. Enterprises shall actively apply for renewal 3 to 12 months before the expiration date.

(2) Cold storage facilities also require registration: Cold storages storing terrestrial animal-derived food and aquatic products are included in the scope of GACC registration management.

Part 2: Key Impacts of the New National Standard GB 2762-2025 on Imported Meat

GB 2762-2025 will be officially implemented on September 2, 2026, replacing GB 2762-2022 and its No.1 Amendment List as a mandatory national food safety standard. The core change is the shift of heavy metal detection judgment for dried meat products fromconversion calculation to direct judgment.

Old Standard Rule

For dried meat products, the contaminant content of fresh raw materials was measured first, and then converted to the fresh product baseline based on the dehydration rate for compliance judgment. This method has long plagued the industry due to the lack of unified standards for dehydration rate determination, resulting in high testing costs and frequent law enforcement disputes.

New Standard Rule

The conversion provisions for dried meat products are completely deleted. The contaminant limit standards for dried meat products (including dried livestock and poultry offal products) are fully aligned with other meat products, with specific limits (mg/kg) as follows:

• Lead (Pb): 0.3 mg/kg • Cadmium (Cd): 0.1 mg/kg • Total Arsenic (As): 0.5 mg/kg • Chromium (Cr): 1.0 mg/kg

A new sub-category of cooked dried meat products is added under the meat product category in Appendix A of the standard. The limit of N-nitrosodimethylamine remains unchanged at 3.0 μg/kg.

⚠️ Critical Risk: Compliance Result Reversal

The adjustment of judgment criteria may render previously qualified products non-compliant.

Example: If the measured lead content of imported dried meat is 0.8 mg/kg:

• Old standard: Converted to 0.27 mg/kg based on a 3:1 dehydration rate (compliant, below the 0.3 mg/kg limit) • New standard: Direct judgment of 0.8 mg/kg (non-compliant, exceeding the limit)

This means that dried meat products compliant with the old standard may fail customs inspection and face return after September 2, 2026.

Limited Impact on Fresh and Frozen Meat, Increased Raw Material Control Pressure

The contaminant limit values for fresh and frozen meat remain unchanged in this update with limited direct impact. However, since the conversion calculation is abolished for dried products, the heavy metal indicators of fresh and frozen raw materials directly determine the compliance of finished products, greatly raising the raw material control requirements. Overseas manufacturers must strictly control raw material quality and ensure heavy metal indicators of fresh meat are far below the finished product limits.

Clearer Product Classification

The official addition of the "cooked dried meat products" category eliminates compliance disputes caused by ambiguous product classification.

Part 3: Countermeasures and Suggestions for Importers

With less than two months remaining before the implementation of the new standard on September 2, immediate targeted adjustments are recommended:

1. Full product line inspection: Sort out all dried meat product categories, conduct finished product direct testing in accordance with the new standard, and verify the compliance of four key indicators (lead, cadmium, total arsenic, chromium), with priority given to high-risk products.

2. Strengthen supply chain management: Recommunicate compliance requirements with overseas suppliers, request new standard-compliant test reports, and redefine internal control standards for heavy metal raw materials.

3. Optimize quality control system: Shift the quality control logic from "raw material conversion mode" to "finished product direct judgment mode", and establish a new internal control system based on finished product testing.

4. Optimize transition period arrangement: Sort out the arrival time of in-transit goods and arrange pre-inspection for batches before and after September 2 in advance.

5. Verify factory registration status: Check the validity of overseas factory GACC registration via the CIFER system before shipment.

6. Arrange meat registration renewal in advance: Meat enterprise registration cannot be automatically renewed. Enterprises with expiring qualifications shall submit renewal applications 3-12 months in advance.

GACC registration is the market access qualification, and the new national standard is the product quality threshold. Both are indispensable. Unregistered factories cannot deliver goods to China, and non-compliant products will face return even after arrival. With the upcoming implementation of the new standard, importers shall prioritize compliance preparation to ensure stable business operation after September 2026.

RingOne

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