Exporting to China. Price isn't the barrier, registration is.
In almost every market, the negotiation starts with the product and ends with compliance. With China the order is reversed, and anyone who doesn't know that loses months.
What you need, in a line: a facility registered in China, the four standard shipping documents, a label in Chinese, and your product category checked on the portal. The order matters: registration comes before everything else.
The facility has to be registered before you sell. Chinese customs keeps a register of overseas facilities authorised to export food to China, searchable and managed through the CIFER system. Without a registration number, the goods don't get in.
A new decree has applied since 1 June 2026. Decree 280, issued on 14 October 2025, replaced Decree 248 of 2021 and redesigned the procedure, with registration valid for five years and renewable.
Requirements vary by product category, and they change often. This page doesn't publish the list of categories, because a list like that goes out of date within months: look it up on the portal, with your category in hand.
This guide covers food in general. For two products the route changes before the country even comes into it: wine travels with excise duty and its accompanying document, and olive oil has marketing and labelling rules all of its own. If you export either to China, read this guide and the one for your product. For wine, the market detail is in wine labelling in China.
This piece is part of the guide to export operations for small food producers, and it's deliberately short. In a market that rewrites its rules every few years, a long page is a page that will be wrong before anyone reads it.
The template, to download
Fifteen rows in five stages, in this market's reversed order: before the negotiation, registration, before shipping, the shipment, afterwards. Each row says where to check. At the bottom, four cells for the details to keep to hand: the category, the registration number and its expiry date.
| File | Contents | Link |
|---|---|---|
| ChinaExcel, one sheet | The five stages, a Status column with a drop-down, the source for each row, and four cells for category, registration number and expiry. |
The files are free. There's no form in the way, we don't ask for an email address, and we don't get notified when anyone downloads them. The sheet doesn't list categories, forms or duty rates, for the same reason this page is short: in this market, a detailed but outdated list does more harm than a pointer to the portal.
What you need to export food to China, and in what order
To export food to China you need, in this order: your product category checked on the portal, your facility registered with Chinese customs, a label in Chinese, and the standard shipping documents. Registration comes first: without a registration number, the goods don't get in.
In most markets you can negotiate, agree a price and sort out compliance while the first shipment is being prepared. Not with China: without a registered facility there's no shipment to prepare, and registration takes time that doesn't depend on you.
The commercial consequence is very real. A Chinese buyer asking you for a price already assumes you're registered, and finding out otherwise late in the negotiation wipes out the credibility you've built. Better to say so straight away, with the expected date.
What has changed since 1 June 2026
Decree 280, issued on 14 October 2025 by China's General Administration of Customs and in force since 1 June 2026, replaced Decree 248 of 2021. The most significant change for a small producer is about who applies, and for which categories.
Under the previous regime, applications always went through the competent authority of the exporting country. The new framework adds registration by list alongside that 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 Chinese customs.
For businesses meeting the requirements set by Chinese customs, registration is automatically renewed for a further five years when it expires. The official list of categories subject to recommended registration is the thing to keep an eye on, because it decides which of the two routes you have to take.
Where to look, in practice
| Step | Who does it | Where |
|---|---|---|
| Check the categorybefore anything else | You, with your product's code and description. It decides whether you need a recommendation from the Italian authority or can apply directly. |
The registration system for overseas food exporters to China, where you can look up categories and lists. |
| Register the facilitythe real gateway | The business, with identification documents, a declaration of compliance and, where required, a recommendation from the competent authority. |
Again in the same system, which issues the registration number to show on the packaging and documents. |
| Origin and dutiesno preference | You. The European Union has no free trade agreement with China, so there's 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's no preference to claim. |
The official portal is the registration system for overseas enterprises exporting food to China, available in Chinese and English. That's where you can look up the lists of facilities already registered and the product categories, and where the application goes.
Two things to ask the buyer
First: the exact category Chinese customs puts your product in. Second: whether they've already imported products in that category, and from which facility. A buyer who answers both precisely knows what they're doing.
A buyer who can't answer isn't necessarily unreliable, but the negotiation changes character: you're dealing with someone who'll have to learn alongside you, and that learning time needs to be factored in before you promise a delivery date. On how to tell the difference, see qualifying a foreign buyer.
Why this page isn't longer
There are very detailed guides to China around, listing categories, forms and steps. The problem with those guides is rarely their quality. It's that the subject keeps changing, and a detailed but outdated list does more harm than a short page that tells you where to look.
We checked the date and substance of the change of decree against regulatory sources that specialise in Chinese regulations, and we opened the official portal. We couldn't open the Chinese customs administration's own website, and we say so here rather than pretend otherwise.
When a distant market's deadlines get lost
A registration valid for five years looks like a problem solved for five years. In practice it's a deadline nobody checks for four years and eleven months, and it turns up on the eve of an order, when reopening it takes time you don't have.
It's the kind of date that needs to come out of people's memory and into a place that watches it by itself, with operational deadline alerts. With one rule that matters more than the technology, set out in Ethics: the system prepares and flags, but no document goes out until a person has read and approved it.
In this market there's only one question that matters, and it isn't price. If you send us your product, we'll check on the portal which category it falls into and whether your facility is already registered. It's a public check, we know how to do it, and we'll do it without asking anything of you.
You'll hear back from a person, the same one who builds the systems, within 24 hours, with a read of your situation rather than a quote. Get in touch here; one line is enough.
Questions and answers
What do you need to export food to China?
First and foremost, registration of your production facility with Chinese customs, which keeps a register of authorised overseas facilities and manages it through the CIFER system. Without a registration number the goods don't get in.
It's the reverse of the usual order: in China, compliance comes before the negotiation, not after. A Chinese buyer who asks for a price assumes you're 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.
Alongside applications made through the competent authority of the exporting country, the new framework adds registration by list, where the country's authority submits a list of recommended facilities. Registration is valid for five years.
Who applies for registration, me or my buyer?
Not the buyer. Registration covers the production facility, so you, and it goes through the CIFER system. Depending on the product category, it may require a recommendation from the competent Italian authority.
That's why the first question to ask the buyer is the exact category Chinese customs puts the product in: the answer decides which route you have to take.
Do you need an EUR.1 to export to China?
No, and it wouldn't do anything. The European Union has no free trade agreement with China, so there's 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 certifies the “made in” and gives no right to any reduction. The difference between the two documents is explained on its own page.
How long does registration last, and does it need renewing?
Registration is valid for five years. For businesses that meet the requirements set by Chinese customs, it's automatically renewed for a further five years when it expires.
The practical risk isn't the renewal itself; it's that nobody looks at a five-year deadline until it's imminent, and by then reopening it takes time a negotiation in progress doesn't have.
Notes on sources
- Registration system for overseas enterprises exporting food to China (CIFER), the official portal in Chinese and English, opened and checked on 6 September 2026. This is where you can look up 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 since 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 wouldn't open for our tools, and we say so: we haven't read the primary source.
- This page doesn't publish the list of product categories subject to recommended registration, or forms, or duty rates. In a market that has rewritten its rules twice in five years, a detailed but outdated list does more harm than a pointer to the portal.
With China, the right question comes before the price.
What's the category, and is the facility registered: two questions that can move a negotiation by months. At Itria we start from the outside and build tailored digital systems for exporters. For you, that means more enquiries, fewer losses and less manual work. Drop us a line about what's slowing you down. We'll make the first move: we'll look at what a buyer sees when they search for you, and tell you what we found. Even if we never end up working together.