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Exporting soft drinks and other beverages from China

Drinks are food in Chinese law. A beverage for export comes from a producer filed with customs, meets the importing country's standards or the contract, and is inspected by customs where it is made, which issues the certificate. 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
Standard to meet
The importing country's, or the contract
Certificates
Issued by customs after inspection
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. 2Which standard does the drink have to meet: the destination's or the contract's? Read more
  3. 3Has customs at the place of production inspected the lot and issued the certificate? Read more
  4. 4Does it contain animal or plant products that need quarantine? Read more
  5. 5Are the declaration documents ready 24 hours before loading? Read more
  6. 6Is a certificate of origin needed? Read more

The rules, by area

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

Drinks as food

Soft drinks, waters and juices 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).
  • GACC Decree No. 249 applies to import and export food production and trade, and to customs' supervision of it; food additives and food-related products follow other GACC rules (Article 2).

How we help: Compliant Always keeps the recipe, specifications and test results with each product, 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

Animal and plant quarantine

Quarantine for animal and plant products leaving China.

  • The owner or its agent reports animal and plant products and other quarantine objects to the port quarantine authority before they leave China (Law on Entry and Exit Animal and Plant Quarantine (进出境动植物检疫法), Article 20).
  • Products that pass, or pass after treatment, may leave; customs releases them on the quarantine certificate. Those that fail with no effective treatment may not (Article 21).
  • They are reported again if the destination changes to one with different requirements, if they are repacked or consolidated, or if the quarantine period runs out (Article 22).

How we help: Compliant Always keeps quarantine certificates with the lot and shows which ones a change of route or packing has made stale. 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
ProducerFiling with customs, its control system and records, and meeting the destination's standards.Records and test results kept with each lot, ready for customs and the buyer.
Exporter (consignor)Applying for supervision before declaration and declaring the goods truthfully.The certificates 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 soft drinks and other beverages 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

Are soft drinks 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 drinks follow the export food rules.
Does a beverage maker 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; Food Safety Law, Article 99).
Which standard must an exported drink 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 drinks?
Customs, after on-site checks and sampling show the lot meets the requirements (GACC Decree No. 249, Article 51).
What must the shipping cartons of an exported drink show?
The producer's filing number, the product name, the production batch number and the production date (GACC Decree No. 249, Article 46).
Do containers for exported drinks need inspection?
Ship holds and containers carrying perishable food are inspected before loading at the carrier's or packer's request (Law on Import and Export Commodity Inspection, Article 18).
How long must a beverage exporter keep its 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).
What if a destination reports a problem with a drink exported from China?
GACC investigates and can tighten sampling, require lot-by-lot test reports from a qualified laboratory, or withdraw its registration recommendation (GACC Decree No. 249, Article 54).
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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