Note: This Member Alert replaces the Member Alert issued on April 19. Further clarifications from AQSIQ are noted below and make the information in the April 19 inaccurate.

Chinese Decree 152, issued in March 2011, is an overarching food-safety law encompassing dairy product imports and exports. Decree 152 goes into effect for all dairy products shipped after May 1. The decree outlines requirements for dairy product imports, including a new requirement for certificates of analysis (COA) on first time shipments.

According to Decree 152, “a test report of items listed in the corresponding national standards of food safety is required in the event that dairy is imported for the first time.” A “first time” shipment is defined as any shipment that has changed an overseas producer, product name, formula, overseas exporter, importer or port of entry. Below are tables that outline the COA requirements for “first-time” shipments for dairy products most commonly exported to China.

The General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) has instructed exporters and border inspection officials that all shipments arriving after May 1 will be considered “first time” shipments. Any “first time” shipment exported after May 1 must be accompanied by a COA demonstrating compliance with Chinese national standards (outlined in the tables below). AQSIQ has advised USDEC that lactose is not subject to the requirements of Decree 152.

Guidance on non-first time shipments was distributed in the April 24 Member Alert. If you have any questions, please contact Matt McKnight (mmcknight@usdec.org) or Mitch Bowling (mbowling@usdec.org) at 703-528-3049.