context: The disputable regulation on suspending cold-chain imports from overseas exporters with products contaminated by COVID-19 was removed. But risks of suspension or even ban of food trade still exist.

Having been in place for nearly two years, GAC’s (General Administration of Customs) counter-COVID measure which stipulated immediately suspending cold-chain imports from exporters whose products were found to be contaminated by COVID-19, has been lifted, according to the latest announcement. Although the pandemic is still lingering worldwide, cases of contaminated frozen goods reported by GAC significantly dropped recently, said Li Zhengliang 李政良 GAC department of health and quarantine deputy director.

Exempting exporters from week-long trade suspension is a sign of the state’s willingness to streamline the logistics process, but does not necessarily indicate a softening of COVID controls at Customs. The responsibility of inspection is further moving upstream to exporting countries, explained Li. In H1 2022, GAC conducted video inspections of 182 overseas cold chain producers and held 208 conferences with local regulators. Overseas partners actively cooperated with GAC to prevent and eliminate risks of contamination, Li noted approvingly.

This is likely to be a long-term measure written into GAC’s Decree 249 (Measures for the administration of import and export food safety) and Decree 248 (Provisions on registration administration of overseas manufacturers of imported food)

  • Decree 249 allows Chinese authorities to suspend or ban certain imported food if it is contaminated by pathogens of infectious diseases, or if there is evidence indicating that the food could become a vector of infectious diseases.
  • according to decree 248, where GAC finds that an overseas producer no longer meets the registration requirements, it shall order the enterprise to make rectification within the time limit, and the food from the relevant enterprise exported to China shall be suspended during the period. Producers who still fail to meet requirements after rectification will have their registration revoked.