The new regulations not only change the registration procedures but also shift strongly towards a risk-based management method, requiring export businesses to be more proactive in improving their food safety management systems, traceability, and standardizing documentation.

From June 1, 2026, new regulations on the registration of food manufacturing enterprises exporting to China, under Order 280 of the General Administration of Customs of China (GACC), will officially take effect, replacing Order 248 which has been in effect since 2022.

According to Mr. Ngo Xuan Nam, Deputy Director of the Viet Nam SPS Office (Viet Nam National Notification and Inquiry Point on Sanitary and Phytosanitary Measures), previously, under Order 248, businesses could register in two ways: through the competent authority of the exporting country or by registering directly. 

However, with Order 280, these two methods have been merged. Businesses will proactively submit their applications directly on the CIFER system of the General Administration of Customs of China.

Depending on the product group, the registration dossier may need to include inspection reports, confirmation letters, or recommendations from competent Vietnamese authorities. This requires businesses to coordinate closely with the regulatory agency before finalizing the dossier.

Currently, approximately 90,000 businesses from 178 countries have been approved to register on the CIFER system to export food to China. Of these, nearly 4,000 establishments in Viet Nam have been granted registration codes.

According to the new regulations, the validity period of the business registration code remains at 5 years. However, Order 280 allows businesses to submit renewal applications within a period of 3-12 months before expiration, instead of only 6 months as before.

This regulation is considered more flexible, but regulators warn businesses to regularly monitor registration deadlines. In fact, there have been many cases recently where businesses had their registration codes locked due to forgetting to renew them on time.

When the registration code expires on the CIFER system, businesses will be unable to continue exporting to China until they complete the re-registration process.

In addition to Order 280, GACC also issued Notice 219, which stipulates a list of 2,589 agricultural products that require confirmation letters from the competent authority of the exporting country when registering. This list expands the range of items compared to previous regulations, so businesses need to carefully study it to avoid errors during the registration process.

According to Mr. Nguyen Quy Duong, Deputy Director of the Department of Crop Production and Plant Protection, Order 280 is not simply a change in registration procedures but also reflects a change in China's management of imported food.

Previously, many businesses considered obtaining a registration code as the "ultimate goal" for exporting to China. However, with the new regulations, the registration code is only the first step in the monitoring process.

Accordingly, GACC will intensify regular or unscheduled inspections of businesses throughout the validity period of the registration code. In case of detecting violations of food safety or inadequate management systems, businesses may be required to rectify the issues, temporarily suspend imports, or even have their registration revoked.

"Risk-based management means that the regulatory agency will assess the entire system of the business, from raw material sources, production processes, food safety compliance history to product consumption methods," Mr. Duong said.

According to Mr. Duong, the line between administrative errors and compliance errors is becoming increasingly blurred in the new management system. A business may possess a production facility that meets standards but still be rejected if its declarations are inaccurate. Conversely, a complete set of documents but a weak internal management system can also lead to failure during online or on-site inspections.

Viet Nam is well-suited to adapt.

For products that already have bilateral protocols or agreements between Viet Nam and China, such as durian, bananas, passion fruit, or certain seafood products, the registration process will continue to follow the current mechanism through the competent authority.

For businesses that previously registered under Order 248, the registration code remains valid and does not need to be re-registered under Order 280, except for products falling within the scope of Notice 219.

According to Mr. Nguyen Quy Duong, businesses need to pay special attention to reviewing their product catalogs to accurately determine the registration requirements under the new regulations.

Some products that previously did not require certification from regulatory agencies are now mandatory under the new regulations. Failure to follow the correct procedure may result in businesses being disqualified from the registration system and unable to export to China.

In the past, there have been cases where 118 Vietnamese businesses had their registration renewal function locked on the CIFER system due to failure to monitor information and submit documents on time. When the system is automatically locked, processing documents becomes difficult and directly affects export activities.

According to the SPS Office of Viet Nam, during the drafting of Order 280, Viet Nam proactively participated in providing feedback to China through diplomatic and technical channels.

Numerous conferences to disseminate the new regulations have also been held since the end of 2025 to help localities, industry associations, and businesses stay updated with the latest information.

The Chinese side plans to organize training courses on the new registration system by the end of March 2026. Following this, the Ministry of Agriculture and Environment and relevant Vietnamese agencies will continue to organize further training programs to support businesses.

According to Mr. Ngo Xuan Nam, with a transition period until June 1, 2026, Vietnamese businesses have sufficient time to prepare and adapt to the new regulations if they proactively update information and complete their applications early.

"Business registration is no longer just a simple administrative procedure, but has become part of the food safety management system. Businesses need to view this as a continuous operational process, in which documentation, facilities, testing, personnel, and traceability must be synchronized," Mr. Nam emphasized.

Source: VGP