WITH Australian food exports to China showing steady growth, ChemLinked’s China Food Regulatory Conference brought insightful analysis on the latest food regulatory trends and outcomes from China to Australia.

ChemLinked is an Asia-Pacific regulatory information platform, a product of REACH24H Consulting Group. The conference was its first offline China food & cosmetic seminar in Melbourne.

Amongst topics covered at the event, special foods took centre stage. This is due to the product category’s dynamic growth in China as well as the ever tightening regulatory requirements for market access.

Within the special food category, product types such as infant formula, health food, and food for special medical purpose (FSMP) were highlighted in presentations by ChemLinked’s speakers.

Subsequent topics on CNCA registration, China Food Safety Law (FSL) rules of implementation and food contact materials further detailed China’s food supervision system and notable aspects of compliance for all food product categories intended for the China market.

The conference was organised in collaboration with Complementary Medicines Australia (CMA), the Australian Institute of Food Science & Technology and Australia-China Business Council (ACBC).

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Raising the bar for China infant formula registration

Maxwell Heston, a regulatory compliance specialist with REACH24H, delivered two presentations on China FSL implementation rules and a comprehensive compliance guide to successful infant formula registration in China.

As China’s food market continues to rapidly evolve, so does the strictness of food safety requirements within China’s supervisory system, albeit at a much slower pace.

Within special food category, infant formula has had the most embattled past with food safety in China, in particular citing the 2008 Sanlu melamine scandal. To revive its domestic market and ensure safety for consumers, Chinese authorities have consistently implemented higher quality and sanitary standards for infant formula.

Now the keys to successful formula registration lie in providing evidence that your enterprise has adequate R&D capacity to formulate a recipe that is not only scientifically based and compliant with product requirements but also distinct from other formulas in the market.

Furthermore, on-site inspection of R&D capacity is now a pre-requisite to registration approval, previously this would be conducted after registration approval.

A growing interest in health food

Food regulatory technical expert Yu Yuanzhao discussed the growing trend of overseas health food exported to China. Another sub-category within China’s special foods, health food from Oceania is in very high demand from Chinese consumers due to a strong perception of quality associated with the Australia brand.

Yuanzhao’s presentation laid out the two existing management systems for health food: filing for health foods that supplement nutritional intake i.e. vitamins and minerals and registration for health food claiming a specific function to help regulate the body’s health.

Many of the regulations and requirements for both systems are currently under revision and we expect official implementation to be carried out within the next few years.

High Time for FSMP

Up to now, 18 food for special medical purpose (FSMP) products have been successfully registered in China by both domestic and overseas enterprises.

However, currently revisions to the implementation rules for domestic FSMP production are underway with industry awaiting their release.

This means, at present, domestic FSMP manufacturers are not allowed to produce FSMP as they lack the required production certificate irrespective of their product formula already gaining approval.

To this Yuanzhao noted, “This unprecedented situation offers a considerable advantage for overseas enterprises”.

If we consider the current supply gap of domestic FSMP product in addition with extension of CBEC grace period into 2019 allowing unregistered overseas FSMPs to continue to be sold online, this is a great time and place for Australian special food manufacturers to enter the China market.

Extending the grace period for cross-border e-commerce (CBEC)

Unlike general trade, CBEC channels do not require registration of special food products. Therefore, a heavily discussed topic this past year in the food industry was whether China’s CBEC channels would implement registration of special foods as a pre-market requirement.

In recent years, the Chinese government announced a few times this ensuing change in policy, but have yet to formally set a date for official implementation. The recent announcement this past week to yet again extend the CBEC ‘grace period’, allowing unregistered special foods to continue to utilize CBEC channels, is a most advantageous opportunity for Australian exporters of special foods in gaining unfettered access to the Chinese market.

Chemlinked is expected to continue this successful first landing in Oceania, and will be organising follow-up seminars on food in 2019.

No reference guide for animal testing

A heated topic nowadays is the requirement for animal testing. An interesting development was shared by Yuanzhao, who explained that currently the health food registration policy has reached an impasse due to the repeal of the Technical Specification for Health Food Testing and Evaluation earlier this year.

Therefore, as there is currently no reference to guide the industry in the requirement for animal testing and clinical trials, this leaves the door open to more optimistic developments in this field.

 

About Chemlinked and REACH24H:

REACH24H is an internationally renowned technological services company with its headquarters in Hangzhou, China and branches in Dublin, Washington D.C, and Taiwan. The company has a number of internationally certified toxicologists, specialised safety appraisers, and risk assessment experts who provide first level consulting services on chemicals, agrochemicals, food, cosmetics and consumer products.

ChemLinked was created by REACH24H to provide professionals across the globe with highly reliable, timely and easily understandable food, chemical, cosmetic and agrochemical market access information and help our client’s products enter and stay in Chinese and AP markets. Chemlinked focuses on analysing past, current and pending regulatory and legislative changes, compiling need-to-know substance/ingredient inventories, interpreting and forecasting regulatory trends, reporting regulatory, industry and market news, compiling expert reports and curating its own comprehensive database of Chinese and AP region legislation and regulations.