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Exporting alcoholic drinks from China

Alcoholic drinks are food in Chinese law, so they come from a producer filed with customs, meet the importing country's standards or the contract, and are inspected where they are made. Exported alcohol is exempt from consumption tax unless the State Council provides otherwise. The exporter declares the goods at least 24 hours before loading.

Updated · Each section links to the official source it comes from

Legal status
Food, under the Food Safety Law
Plant filing
With the customs where the producer is domiciled
Certificates
Issued by customs after inspection
Consumption tax
Exports exempt, unless the State Council provides otherwise
Origin
Customs or CCPIT

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Has the producer filed with customs as an export food production enterprise? Read more
  2. 2Does the destination require the producer to be registered through GACC? Read more
  3. 3Has customs at the place of production inspected the lot and issued the certificate? Read more
  4. 4Is the shipment's paperwork kept for the consumption tax exemption? Read more
  5. 5Are the declaration documents ready 24 hours before loading? Read more
  6. 6Is a certificate of origin needed for a preferential tariff? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Alcoholic drinks as food

Alcoholic drinks are food in Chinese law, so the export food rules apply.

  • Food means finished products and raw materials for people to eat or drink (Food Safety Law, Article 150).
  • Export food production enterprises meet the importing country's standards or the contract, and file with customs (Article 99).
  • Where a destination registers Chinese food plants and asks GACC to recommend them, the producer applies through the customs where it is domiciled (GACC Decree No. 249, Article 43).

How we help: Compliant Always keeps the specifications, analyses and certificates for each lot, and reads them against what the destination asks for. Ask about this

Filing of export food production enterprises

Who must be on record with customs before food is exported, and what they must keep.

  • Export food production enterprises and the farms that grow or raise their raw materials file with the entry-exit inspection and quarantine authority, now customs (Food Safety Law (食品安全法), Article 99).
  • Under GACC Decree No. 249, the Administrative Measures on Import and Export Food Safety (进出口食品安全管理办法), in force since 1 January 2022, enterprises file with the customs where they are domiciled, and raw material farms with the customs where they are located (Articles 40 and 42).
  • Exported food meets the importing country's standards or the contract; where neither sets any and no treaty applies, it meets China's national food safety standards (Article 38).
  • The enterprise runs a traceable food safety and hygiene control system, with supplier assessment, incoming inspection, production, release testing, traceability and non-conforming food records kept at least 6 months after the shelf life ends, or 2 years where there is none (Article 44).
  • Exporting food made by an enterprise that has not filed, or not using filed farms' raw materials, is a breach penalised under the Food Safety Law (Article 72).

How we help: Compliant Always keeps the filing number, supplier records and release tests with each lot, dated, and shows what is missing before a shipment. Ask about this

Inspection, certificates and packaging marks

How customs checks exported food and issues the certificates that travel with it.

  • Exported food is inspected and quarantined by the customs at the place of production, unless GACC designates another place (Decree No. 249, Article 48).
  • The producer or exporter applies to the customs where the food is produced or consolidated for supervision before the export declaration (Article 49).
  • Food that passes on-site checks and sampling receives a certificate from customs and may be exported; food that fails may be treated and re-inspected, or may not be exported (Article 51).
  • Customs also checks exported food at the port, and food that fails is not exported (Article 53).
  • The transport packaging shows the enterprise's filing number, product name, production batch number and production date (Article 46).
  • Ship holds and containers for perishable food are inspected before loading at the request of the carrier or packer (Law on Import and Export Commodity Inspection, Article 18).

How we help: Compliant Always keeps each certificate with the shipment and lot, dated, and reads it against what the destination asks for. Ask about this

Consumption tax on exported alcohol

Alcohol is a taxable consumer good in China, and exports are exempt.

  • The tax table of the Interim Regulations on Consumption Tax (消费税暂行条例) lists alcohol (酒), including baijiu, huangjiu, beer and other alcoholic drinks.
  • Taxable consumer goods exported by a taxpayer are exempt from consumption tax, unless the State Council provides otherwise (Article 11).
  • The exemption procedure is set by the finance and tax authorities of the State Council (Article 11).
  • The regulations were revised in 2008 and have applied in that form since 1 January 2009; the State Taxation Administration's database lists them as in force.

How we help: Compliant Always keeps the export declaration and the shipment's documents together, dated, so the record behind an exemption claim is in one place. Ask about this

Export declaration and customs recordation

Who may declare goods for export, when, and with which documents.

  • The consignor of exported goods may declare to customs itself or authorise a customs declaration enterprise; either must complete recordation with customs in advance (GACC Decree No. 277, Article 4).
  • Declaration is made on the electronic customs declaration form; a paper form may be used only in special circumstances with customs' consent (Article 5).
  • Exported goods are declared after they arrive at the area under customs supervision and at least 24 hours before loading (Article 7).
  • The accompanying documents are the contract, invoice, packing list, manifest, bill of lading or waybill, power of attorney for customs declaration, export licences and other documents required by law; goods subject to inspection and quarantine need the documents set for them (Article 8).
  • The consignor and the declaration enterprise answer for the veracity, accuracy, integrity and compliance of what is declared (Article 6).
  • Recordation of a customs declaration entity is valid for a long time; changes to the name, domicile, legal representative or declaration personnel are reported within 30 days (GACC Decree No. 253, Articles 8 and 9).

How we help: Compliant Always keeps the contract, invoice, packing list and any licence with the shipment and lot, dated, and shows what is missing before the goods reach the port. Ask about this

Certificates of origin

Proof that goods originate in China, for non-preferential purposes and for preferential tariffs under trade agreements.

  • A consignor may apply for a certificate of origin to the inspection and quarantine authorities, now part of customs, or to the China Council for the Promotion of International Trade (CCPIT) and its local sub-councils (Regulations on the Origin of Import and Export Goods, Article 17).
  • The applicant registers with the issuing authority and declares origin truthfully; no certificate is issued for goods not originating in China (Articles 18 and 19).
  • Goods wholly obtained in China originate there; otherwise origin is where the last substantial transformation took place, judged first by a change in tariff classification (Articles 3 and 6).
  • Under RCEP, a Certificate of Origin is issued before shipment, or marked "ISSUED RETROACTIVELY"; China's issuing bodies are customs and CCPIT with their local branches (GACC Decree No. 255, Articles 19 and 42).
  • An approved exporter, which must be an Advanced Certified Enterprise, may issue its own declaration of origin under RCEP and the agreements with Iceland, Switzerland and Mauritius; the authorisation lasts 3 years (GACC Decree No. 254).
  • Consignors, manufacturers and approved exporters keep the documents proving origin for 3 years from issue (Decree No. 255, Article 41).
  • Obtaining a certificate by fraud, or forging or trading one, is fined 5,000 to 100,000 yuan (Regulations on Origin, Article 23).

How we help: Compliant Always keeps each certificate or declaration of origin with the shipment, beside the bill of materials it rests on, for the three years the records are kept. Ask about this

Who answers for what

WhoWhat they answer forHow we help
Producer (distillery, brewery or winery)Filing with customs, its control system and records, and meeting the destination's standards.Analyses and records kept with each lot, ready for customs and the buyer.
Exporter (consignor)Applying for supervision before declaration, declaring truthfully, and the paperwork behind a tax exemption.The certificates and declaration for each shipment in one place, dated.
Customs declaration enterprise or forwarderDeclaring within the authority the exporter gives it, under a power of attorney filed with customs.Answers to its questions taken from the record rather than from email threads.
Customs and CCPITInspection, quarantine and export certificates (customs), and certificates of origin (customs or CCPIT).Certificates kept with the shipment and read against what the destination asks for.

Local customs

GACC sets the rules and local customs apply them. Export food production enterprises file with the customs where they are domiciled, and raw material farms with the customs where they are located (GACC Decree No. 249).

Exported food and cosmetics are inspected at the place of production, unless GACC designates another place.

Where are the goods going?

Most of what alcoholic drinks have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

Questions businesses ask

Is alcohol treated as food for export from China?
Yes. The Food Safety Law defines food as products for people to eat or drink (Article 150), so alcoholic drinks follow the export food rules, including filing with customs (Article 99).
Does a baijiu or beer producer need to file with customs before exporting?
Yes. Export food production enterprises file with the customs where they are domiciled (GACC Decree No. 249, Article 42).
Is consumption tax charged on alcohol exported from China?
Taxable consumer goods exported by a taxpayer are exempt, unless the State Council provides otherwise; the finance and tax authorities set the procedure (Interim Regulations on Consumption Tax, Article 11).
Which standard must exported alcohol meet?
The importing country's standards or the contract. Where neither sets any and no treaty applies, China's national food safety standards (GACC Decree No. 249, Article 38).
Who issues the certificate for exported alcoholic drinks?
Customs, after on-site checks and sampling show the lot meets the requirements (GACC Decree No. 249, Article 51).
What must the cases of exported alcohol show?
The producer's filing number, the product name, the production batch number and the production date (GACC Decree No. 249, Article 46).
Does a destination's plant registration apply to Chinese alcohol producers?
Where the destination requires it, the producer and its products must be registered there before export, applying through its local customs for GACC's recommendation (GACC Announcement No. 87 of 2021).
How long must an alcohol exporter keep production records?
At least 6 months after the shelf life ends, or 2 years where there is no set shelf life (GACC Decree No. 249, Article 44).
When must goods be declared for export from China?
After they arrive at the area under customs supervision and at least 24 hours before loading. The consignor declares itself or through a customs declaration enterprise, both recorded with customs in advance (GACC Decree No. 277).
Who issues certificates of origin in China?
Customs and the China Council for the Promotion of International Trade (CCPIT) with its local branches. Approved exporters may issue their own declarations of origin under RCEP and some other agreements.
How does Compliant Always help with exporting from China?
Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

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