Recently, the General Administration of Quality Supervision, Inspection and Quarantine ("AQSIQ") has issued the Administrative Provisions for the Record-filing of Exported Food Manufacturers (the "Provisions"), effective from January 1, 2018.
The Provisions state that the State operates a system of subjecting exported food manufacturers to administration by record-filing. Where an exported food manufacturer fails to perform its statutory obligation to file the record or is found in the record-filing review not to meet relevant requirements, its products will not be allowed to be exported. According to the Provisions, exported food manufacturers shall establish archives to record both how well the food safety and hygiene controlling system runs and the manufacturing processes of exported food, and relevant documents and certifications shall be safekept until at least six months after the shelf life of food has expired; in case the shelf life is not clear, these materials shall be reserved for two years at least. Furthermore, the Provisions expressly state that any exported food manufacturer that falls under any of three listed circumstances, such as "where the exported food manufacturer was subject to three or more notices circulated by the competent authority of the imported country (region) within a year as a result of its own safety and hygiene problems", shall be ordered to make corrections within prescribed time limits, during which its application for having relevant food inspected for the export purpose will not be accepted.