Export of Dairy Products to China: Key Requirements and New Standards

Key Requirements for Access to the Chinese Market

• Full compliance of products with China’s national standards;

• Implementation and maintenance of the HACCP system at production facilities;

• Proof of safety for raw materials, packaging materials, water used, and labeling.

The registration process requires a significant volume of documentation, analysis, and reporting. To facilitate preparation and self-assessment, Agroexport has presented the key requirements in a structured format:

1. Compliance of Dairy Raw Materials with Established Standards

Manufacturers must provide a list of raw materials (e.g., milk powder, whey) and acceptance criteria, including quality indicators and regulatory requirements.
Regulatory documents: GB 19644-2024 (milk powder), GB 11674-2010 (whey).

2. Products Must Comply with Chinese Standards

Registration documents must include the types of dairy products and their corresponding Chinese national standards (for milk powder, cheese, butter, etc.) to confirm compliance with Chinese safety requirements.
Regulatory documents: GB 19302-2010, GB 25190-2010, GB 19644-2024, and others.

3. Use of Approved Enzymes and Additives Only

Manufacturers are required to provide a list of enzymes, strains, and food additives used, including dosages and regulatory limits applied in the production of goods intended for export to China.
Regulatory documents: GB 19302-2010, GB 2760-2024, GB 14880-2012, etc.

4. Packaging Safety

Suitability of internal and external packaging materials must be confirmed to prevent the migration of harmful substances.
Regulatory documents: GB 12693-2023, Section 9.5.

5. Supplier Verification

Procedures for selecting, evaluating, and periodically auditing raw material suppliers must be described to ensure the reliability and safety of the production chain.
Regulatory documents: GB 12693-2023, Section 8.2.1.

6. Implementation of the HACCP System

The manufacturer must, if required, submit a flowchart of production and processing, a hazard analysis table, a HACCP plan, as well as ISO 22000 and ISO 9001 certifications to control critical points in production.
Regulatory documents: GB/T 27341-2009.

7. Production Process Transparency

A technological flowchart must be provided with key parameters (e.g., temperature, thermal processing time) and their