Two years ago, the Chinese government issued Chinese Decree 152, a comprehensive food safety law that regulates all dairy products entering China. The decree asks all exporters of dairy products to register with the Chinese government and includes a new requirement for these companies to hold a certificate of analysis (COA) for all first-time shipments. The decree will go into effect for all dairy products shipped after May 1, 2013.
Just today, Chinese officials clarified the interpretation of the decree to say that each exporter’s first shipment after May 1, whether it’s a first or subsequent shipment to China, will be considered a first-time shipment and will be required to have a certificate of analysis before it will be accepted. All subsequent shipments must also present a copy of the COA that accompanied this first-time shipment.
The first-time certificate demonstrates compliance with Chinese national standards for milk powder, lactose, cheese, butter, whey powder and whey protein powder. The U.S. Dairy Export Council has compiled a list of the tests required to receive the first-time certificate, which members may access by logging in below.
The list is different for dairy products that are part of a subsequent shipment. It’s also available to members who log in below.
Food and Drug Administration officials also announced earlier this week the details regarding the implementation of Decree 145, which has been incorporated into Decree 152. Decree 145 concerns the registration of U.S. companies interested in exporting dairy products to China.
Specifically, FDA reported that they are working on a questionnaire from the Chinese government, which will be completed by the end of the month. Shortly after that, FDA will publish a Federal Register notice seeking the names of U.S. companies interested in exporting to China. This notice will be very similar to the notice issued in 2003 for U.S. dairy exports to Chile.