01 Sourcing and Supplier Screening: Compliance Starts at the Source
The first step for overseas buyers contacting Chinese food suppliers is not negotiating price—it is confirming whether the supplier holds valid export qualifications.
Under China Customs regulations, export food manufacturers must register with the local Customs office and may only produce export food after registration is approved. Buyers can verify this through the following methods:
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Request the supplier to provide the Export Food Production Enterprise Registration Certificate (valid indefinitely).
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Check registration status via the “Internet+Customs” platform (online.customs.gov.cn).
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Confirm that the supplier has established a food safety and hygiene control system based on hazard analysis and preventive controls.
Special Reminder: If your target market is the EU, the U.S., Japan, or other countries/regions that implement registration management for Chinese food exports, verify whether the manufacturer has obtained Customs’ overseas recommended registration.
02 Contacting Customer Service and Quoting: Specifying Product Requirements and Compliance Criteria
When communicating with the supplier’s customer service team, overseas buyers need to clearly convey the following information—this directly affects whether the export can proceed smoothly:
Essential Information Checklist:
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Product name, specifications, quantity/weight, production date: These are mandatory fields for customs declarations.
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Destination country’s food safety standards: China Customs requires that exported foods comply with the importing country’s standards or contractual requirements. If the importing country has no applicable standard and the contract does not specify one, then China’s national food safety standards apply.
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Labeling and packaging requirements: Different countries have different regulations on food labels, allergen declarations, and nutrition facts panel formats—confirm these in advance.
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Transportation and storage conditions: If special temperature control is required, specify this in the contract.
Special Note for FDA Markets: If your shipment is destined for the U.S., all food facilities must be registered with the FDA, and Prior Notice must be submitted for each shipment before it arrives at the U.S. port. Submission timing: at least 2 hours prior for truck shipments, 4 hours for air, and 8 hours for ocean freight.
03 Contract Signing and Production Preparation: Contract and Compliance Documentation
After the purchase contract is signed, the supplier enters the production preparation stage. A series of export documents must be prepared to lay the foundation for customs clearance.
Required Documentation Checklist:
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Contract
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Commercial Invoice
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Packing List
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Factory Inspection Certificate (the enterprise’s own inspection record for its products)
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Raw material supply certification for export food processing (if applicable)
Label Compliance Recommendations: Overseas buyers should request the supplier to provide a product label sample for approval before printing. Labels must include product name, ingredient list (in descending order), net quantity, manufacturer/distributor information, allergen declaration, country of origin, etc.
Ingredient Review: For example, Chinese-origin dairy-containing foods have been on the FDA’s Detention Without Physical Examination (DWPE) list since 2008. For such products, each shipment must provide third-party laboratory test reports using FDA-accepted methods, demonstrating that the product is free of melamine or cyanuric acid.
04 Pre-Export Inspection and Quarantine: Customs “Health Check”
This is the core stage of the export process. The exporter must apply for pre-export inspection and quarantine at the Customs office in the place of production or consolidation, submitting documents including contract, invoice, packing list, and factory inspection certificate.
Customs Processing Workflow:
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System Command Assignment: Based on risk settings, Customs issues one of the following commands: “Direct Release without Inspection,” “On-Site Inspection,” or “Inspection + Sampling for Laboratory Testing.”
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On-Site Inspection (if flagged): Customs checks the consistency of goods with documentation, sensory characteristics of the product, packaging, quantity/weight, and sanitation of the transport vehicle.
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Laboratory Testing (if flagged): Samples are sent to the laboratory for safety and hygiene testing. Test items depend on product category and destination country requirements.
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Comprehensive Assessment: Customs issues a ruling based on declaration information, on-site inspection results, and laboratory test findings.
Important Policy Update: Customs is promoting a “batch inspection (quarantine)” reform pilot program. Under this program, for the first shipment within a “batch inspection unit,” 100% on-site inspection is conducted; for subsequent batches, release may be granted based on document review alone, without repeat on-site inspection.
05 Compliance Assessment and Electronic Manifest Issuance: Obtaining the Export “Passport”
If the product passes comprehensive assessment, Customs generates an electronic manifest record and provides the electronic manifest data number to the enterprise. This number serves as the “passport” for subsequent customs declaration.
Non-Compliance Scenarios: If a product fails inspection, Customs issues a Notice of Unqualified Export Goods and does not permit export. Products that can be reprocessed may be exported after correction; those that cannot be corrected or remain non-compliant after correction are prohibited from export.
Certificate Issuance: If the destination country requires official inspection and quarantine certificates (e.g., health certificate, sanitary certificate), Customs issues these through the “Cloud Issuance” module.
06 Export Declaration and Port Inspection: The Final Checkpoint Before Departure
After completing jurisdiction-based inspection and quarantine, the exporter or its customs broker submits the export declaration through China’s International Trade “Single Window” platform. The following documents must be submitted:
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Power of Attorney for Customs Brokerage (applicable only when using a broker)
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Export food electronic manifest data number (core document)
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Relevant permits and accompanying documents
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Commercial documents (invoice, packing list, etc.)
Port Customs Actions: Customs conducts random inspections at the port, verifying consistency of product name, batch number, specifications, quantity, and transport packaging markings, and ensuring packaging is intact. Goods that pass port inspection are cleared for release.
07 International Transport and Overseas Clearance: Arriving at the Destination Market
After goods leave China and enter international transport, overseas buyers must focus on the destination country’s clearance requirements.
Special Guidance for the U.S. Market:
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Prior Notice: Must be submitted to the FDA before the shipment arrives at the U.S. port and must receive confirmation. Timing: at least 2 hours for truck, 4 hours for air, and 8 hours for ocean freight. Shipments without Prior Notice will be detained jointly by CBP and the FDA.
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Types of FDA Review:
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FDA Review: Electronic information review passes—usually direct release.
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FDA Hold/Documents Required: FDA requests additional documentation (commercial invoice, packing list, label copies, etc.).
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FDA Exam Sample: Most stringent review—the FDA may physically sample the goods for testing.
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“May Proceed” Signal: Only after receiving the FDA’s “May Proceed” notification is the shipment formally released for entry into the U.S. market.
For DWPE-Listed Products: For dairy-containing foods subject to automatic detention, prepare third-party test reports in advance to avoid clearance holds.
08 Practical Recommendations for Overseas Buyers
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Verify Supplier Qualifications Before Ordering: Request the supplier to provide Customs registration documentation and confirm they are qualified to produce export food. Use the “Internet+Customs” or “Single Window” platforms for online verification.
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Specify Destination Country Standards in Contracts: Include the importing country’s food safety standards, labeling requirements, and test items in the contract as the basis for supplier performance.
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Request Full Compliance Documentation: Require suppliers to provide factory inspection reports, third-party test reports, ingredient lists, and label samples. Comprehensive documentation significantly reduces the risk of customs holds.
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Allow Sufficient Lead Time: Customs inspection and quarantine may take several days—especially when laboratory testing is required—so build buffer time into your production schedule.
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Pay Special Attention to Prior Notice for U.S. Exports: Ensure that the supplier or freight forwarder submits FDA Prior Notice at least 2–8 hours before the shipment arrives at the U.S. port, and complete FDA facility registration in advance.
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Understand “Automatic Detention” Risks: For product categories listed on the FDA’s DWPE list (e.g., dairy-containing foods), coordinate with the supplier on third-party testing to ensure each shipment is accompanied by a valid test report.
Ordering food from China for overseas buyers is fundamentally a relay race of compliance. From supplier registration to export inspection, from electronic manifests to FDA Prior Notice—a single oversight at any step can result in an entire shipment being held at port. Doing your homework upfront, selecting a compliant supplier, and preparing a full set of documentation are the only surefire ways to ensure your goods arrive safely.
