Attention Please,Overseas Foods OEM/ODM Factories!

If you providing OEM/ODM services for Chinese domestic brands,there's a big, unavoidable change-GACC Order No. 280.

From June 1, 2026, China will officially implement GACC Order No. 280, revising the registration and management of overseas manufacturers of imported food.

The new regulations will replace GACC Order No. 248, which had been in effect since 2022 and regulated the registration of overseas food manufacturers. For overseas OEM factories producing dietary supplements, functional foods, and nutritional products for Chinese domestic brands, this change will reshape compliance requirements and your long-term cooperation model with Chinese partners.

What are the changes?

Under the previous system (Order No. 248):

• Overseas OEM factories supplying Chinese domestic brands needed to obtain GACC registration.

• Certain product categories (e.g., dietary supplements which raw materials are krill oil or krill peptides ) required official recommendations from the relevant domestic authorities.

• The previous system used a fixed list of 18 food categories, requiring official recommendations.

Under the new system (Order No. 280):

• This regulation introduces a risk-based registration framework, consistent with China's food safety regulatory principles.

• The existing fixed category list will be replaced by a dynamic catalog managed by the State Food and Drug Administration (GACC), which will be adjusted from time to time based on risk assessment results.

• Overseas contract manufacturers must register in their own name through a unified official process, regardless of OEM cooperation.

• Registration is valid for 5 years, and most continuously compliant factories can automatically renew; high-risk categories are not eligible for automatic renewal.

• This regulation will be fully implemented on June 1, 2026, at which time old registration numbers under Order No. 248 will become invalid.

What does this mean for overseas contract manufacturers serving Chinese domestic brands?

Your GACC registration status directly determines whether your Chinese domestic brand partners can successfully complete import customs clearance.

Even if your partners are currently using cross-border e-commerce channels, if they plan to switch to traditional import channels (whether offline or online), your factory must fully comply with the latest registration regulations. Failure to meet the relevant requirements will lead to customs clearance delays, resulting in high storage costs, delayed market demand, and damage to your cooperation with Chinese brands and your reputation.

Furthermore, your GACC registration number (the 18-digit code consisting of 4 uppercase letters and 14 numbers) must be printed on both the inner and outer packaging of products exported to China; this is mandatory.If your registration expires, all printed packaging will be invalidated, causing losses to your factory and your Chinese partners.

 

Follow-up Recommendations for Overseas OEM Factories

1️⃣ Check your factory's current GACC registration status, confirm the validity period of the registration number, and verify on the official GACC website that it has not been suspended or revoked.

2️⃣ Confirm whether your products manufactured for Chinese domestic brands will be included in the GACC dynamic risk list; if they belong to a high-risk category, please confirm that you have obtained official advice from the relevant authorities in your home country.

3️⃣ Prepare the latest documents required for factory registration or renewal, including corporate identification documents, food safety management system documents, and (for high-risk categories) inspection reports and recommendations from your home country's competent authorities.

4️⃣ Proactively communicate with your Chinese local brand partners to confirm their import channels and adjust your compliance strategy to meet their needs, thereby avoiding potential customs clearance risks.

China remains one of the world's largest and fastest-growing nutritional supplement markets, and maintaining stable partnerships with Chinese local brands is key to your long-term development in this market.

Being regulatory prepared is crucial to maintaining your competitive advantage and stable cooperation with your Chinese partners.

If you are an overseas OEM factory producing dietary supplements or functional foods for Chinese local brands, reassess your compliance roadmap before new regulations take effect to be fully prepared for the rapidly changing market.