Do you need GACC registration to sell Canadian food in China? What changed on June 1, 2026

Short answer: In most cases, yes: if a facility makes or processes food you plan to ship to China, that facility generally has to be registered with China's customs authority, the General Administration of Customs (GACC), before the food can be exported, under GACC Decree 280. The same generally goes for a cold store holding meat, dairy, seafood or other animal or aquatic food bound for China, under GACC Announcement No. 27 of 2026. The registration belongs to the facility: guidance from the Canadian Food Inspection Agency (CFIA) says a Canadian trader or brand that only exports, without making, processing or storing the food, doesn't register itself, but the facility that makes the product must be registered. According to CFIA's notice on the change, since Decree 280 took effect on June 1, 2026, 17 food categories need a CFIA recommendation, most registrations now renew automatically, and fresh vegetables, grains, oilseeds, pulses and unroasted coffee and cocoa beans are no longer part of registration in the China Import Food Enterprise Registration (CIFER) system, though they stay under GACC's separate registration run by its Department of Animal and Plant Quarantine.

What Decree 280 is

Registration itself isn't new. CFIA's guidance for industry says Canadian establishments that make, process or store food for China have had to be registered in CIFER since January 1, 2022. What changed is the rulebook behind it.

GACC announced Decree 280 on October 14, 2025. It took effect on June 1, 2026 and replaced Decree 248 (Art. 33, official Chinese text; USDA FAS report CH2025-0204). Under Art. 2, the decree covers overseas facilities that produce, process or store food exported to China, but not facilities that produce, process or store food additives or food-related products. "Food-related products" is a Chinese legal term for food packaging and containers, detergents and disinfectants used for food, and the tools and equipment used to make and sell food, as set out in Art. 2 of China's Food Safety Law.

The obligation sits with the facility, not the trading company. CFIA says Canadian businesses that only export food, without making, processing or storing it, don't need to register with GACC.

GACC set out the implementation details in Announcement No. 27, dated March 18, 2026. You can read the Chinese text on GACC's website or in the State Council policy document library, and USDA FAS has an unofficial English translation in report CH2026-0034.

Which registration route applies to you

The 17 categories that need a CFIA recommendation, as CFIA lists them: meat and meat products; casings; aquatic products; dairy products; bird's nests and bird's nest products; bee products; eggs and egg products; edible oils and fats; stuffed pasta products; edible grains (rice); grain milling industrial products and malt; dehydrated vegetables; seasoning powders; nuts and seeds; dried fruits; special dietary foods; and health foods. In Announcement No. 27, GACC says this catalog is subject to "dynamic management" (FAS translation), so it can change.

A product missing from that list isn't automatically exempt. Maple syrup, for example, isn't named in any of the 17 categories. That doesn't mean a maple producer can skip registration. It most likely means the producer wouldn't need a CFIA recommendation and would register with GACC directly. Under the old rules, CFIA understood that GACC treated every food outside its high- and medium-risk lists as low risk, and CFIA wasn't involved in registering low-risk foods, according to its low risk foods page (modified October 23, 2025). Before you rely on that, check the category in the "Product Type Enquiry" function of GACC's registration system, which, according to Announcement No. 27 (FAS translation), links registration categories to Chinese customs commodity codes.

If you can't tell whether your product belongs in CIFER or with DAPQ, CFIA's notice directs exporters to the Market Access Secretariat single window at Agriculture and Agri-Food Canada: aafc.mas-sam.aac@agr.gc.ca.

What changed on June 1, 2026

• One application process. Decree 248 had two tracks, self-registration and registration recommended by the home authority. Decree 280 uses a single process in which the company submits its documents to GACC; only facilities making foods in the catalog also submit an audit report and a recommendation letter from their home authority (FAS CH2025-0204). In Canada, that authority is CFIA (CFIA CIFER guidance).
• Automatic renewal. A registration is valid for five years and, in most cases, renews automatically for another five (Arts. 15 and 21, FAS unofficial translation). Meat and meat products from land animals (casings excluded) and bird's nests and bird's nest products still need a formal renewal application, and the window is now 3 to 12 months before expiry instead of 3 to 6 (CFIA notice).
• Storage facilities. Cold stores for land-animal and aquatic foods still register; stores holding other products at ambient temperature don't (CFIA notice; Announcement No. 27, section I(III)). For other products, CFIA only mentions ambient storage; if you cold-store non-animal food, such as frozen vegetables, confirm with your importer.
• Primary farm products. Fresh vegetables, grains and oilseeds (CFIA's examples include wheat, barley, canola, soybeans and flaxseed), dried beans including pulses, and unroasted coffee and cocoa beans were removed from the decree's scope. They no longer need CIFER registration, but companies responsible for them must still be registered with DAPQ before export (CFIA notice).

What this means for your business

Use this as a working checklist before your next shipment or buyer conversation:

1. Identify every facility that touches the product. Registration follows whoever makes or processes the food (Decree 280, Arts. 2 and 4: official Chinese text; FAS unofficial translation), plus any cold store holding meat, dairy, seafood or other animal or aquatic food for it (Announcement No. 27, section I(III); CFIA notice). If a co-packer or third-party cold store is involved, ask about its registration early.
2. Verify your supplier's registration. Ask for its 18-digit Chinese registration number for your product category, and check the number and expiry date on GACC's public list of registered overseas producers, the CIFER Query page (Announcement No. 27, section III(II); CFIA CIFER guidance).
3. Settle the product codes with your importer. CFIA says it can't advise on which HS and CIQ codes to enter in CIFER, that establishments should work them out with their Chinese importer, and that wrong codes can delay or prevent clearance.
4. For the 17 categories, start with CFIA. CFIA's guidance says establishments need a Safe Food for Canadians licence that includes the activity "preparing food for export", and it notes that GACC's review timeline is unpredictable. Parts of that page still describe the Decree 248 process, so read it alongside the May 2026 notice. For foods outside the 17 categories, CFIA's low risk foods page, also written under Decree 248, says companies registering in CIFER may not need an SFC licence unless they need one for other reasons, and suggests asking your importer whether China wants a licensed production certificate.
5. Put the number on the package. A registered producer must mark the food packaging with its Chinese registration number or the number approved by its home authority (Art. 14, FAS unofficial translation).
6. Customs declarations (not new). According to GACC Announcement No. 103 of 2021, since January 1, 2022, the import declaration for food shipped to China has had to show the overseas producer's Chinese registration number under licence category code 519. Announcement No. 27 restates this for Decree 280, and customs won't accept a declaration that leaves it out (section II(I): Chinese text; FAS translation).
7. Watch production and expiry dates. According to Announcement No. 27 (FAS translation), food from a facility registered with an official recommendation can still be declared if it was made while the registration was valid and is within its shelf life. For a facility that registered on its own, the registration must be valid on the day of the import declaration.
8. Use only the official system. In Announcement No. 27 (GACC original; FAS translation), GACC names cifer.singlewindow.cn as the registration system, warns companies to avoid fake websites, and says it charges no fee for registration.
9. Treat cross-border e-commerce as its own question. Decree 280 says cross-border e-commerce retail imports are handled under the relevant regulations (Art. 30, FAS unofficial translation), and CFIA's notice tells exporters to work out those requirements with their Chinese importer. Confirm them with your importer or platform before you choose that route.

How QX can help

GACC registration and product classification run through CFIA, AAFC's Market Access Secretariat and your Chinese importer. QX takes care of the market side, so Chinese buyers and consumers can understand your product, find it and get in touch: we map where your product fits in China, prepare your Chinese-language brand and product materials, and run your Xiaohongshu, WeChat and Douyin accounts. Start with a free 20-minute consultation and leave with a clear direction and a practical next step for your product.