Understanding and Interpretation of the Regulations of the People’s Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food (GACC Order No. 280)

Policy Background: GACC Order No. 280 was promulgated on October 14, 2025, and will come into effect on June 1, 2026.

Policy Link: http://www.customs.gov.cn/customs/2025-10/14/article_2025121223530313522.html

Policy Download URL: http://www.customs.gov.cn/customs/fileDir/resource/cms/article/2480148/6775328/2025101416235844898.pdf

Official Policy Interpretation: http://www.customs.gov.cn/customs/2026-10/26/article_2026102617052019328.html

Doing business in any country around the world requires understanding and complying with local laws and regulations, and cross-border e-commerce in China is no exception. All the services we provide must be carried out within the framework of legal and regulatory compliance.

Recently, many of the project cooperation inquiries we have received from overseas clients have centered on GACC Order No. 280 concerning cross-border e-commerce. To reduce communication costs, we have compiled the core information below for your easy reference.

You may have the following questions or needs:

1. Why do I see other companies in the same country as mine that, as far as I know, have not obtained GACC/CIFER overseas manufacturer registration from the General Administration of Customs of China (GACC)?

2. Under the previous 1210-coded cross-border e-commerce bonded stocking model, can we launch a China cross-border e-commerce project test without necessarily obtaining GACC/CIFER overseas manufacturer registration?

3. If compliance with Order No. 280 is mandatory, please provide me with the specific policy link and the official interpretation link. I need to verify the accuracy of the information you provide.

4. If my manufacturing enterprise cannot obtain GACC/CIFER overseas manufacturer registration in the short term, does that mean I cannot launch cross-border e-commerce business in China?

Our Experience and Recommendations:

1. Many enterprises laid out their China cross-border e-commerce business before Order No. 280 came into force—that is to say, they may indeed not have obtained GACC/CIFER overseas manufacturer registration previously. However, the new policy requires all enterprises to comply, which means that registration will definitely be required in the subsequent bonded warehouse procurement and customs clearance chain, as well as in the new product launch chain. It is only a matter of time. For long-term operations, without GACC/CIFER overseas manufacturer registration, there is a 100% likelihood of products being delisted or returned, or even of uncontrollable derivative risks arising.

2. “1210” stands for “Bonded Cross-border Trade E-commerce” and is a customs supervision method code applicable to the bonded stocking model for cross-border e-commerce retail imports. “Order No. 280” is the Regulations on the Registration and Administration of Overseas Manufacturers of Imported Food—it is not a “model” but a customs regulation. Therefore, please do not use “1210” to question whether the requirements of “Order No. 280” need to be met.

3. The policy link and official interpretation are provided at the beginning of this article and will not be repeated here. The key point we want to convey is this: whether a policy is clear or unclear, it is ultimately implemented by people, and you should trust the professionalism of the team that is currently serving China cross-border e-commerce clients. After all, we communicate with customs, bonded warehouses, and customs affairs personnel on various business details every day, and we can promptly identify the relevant person in charge to confirm and communicate. The conclusions we provide are, with high probability, feedback on how things are actually implemented—although there is indeed some information for which we cannot give you a 100% definitive guarantee. In our view, spending hours reading policy documents is far less reliable than actually running through the entire sales process through small-batch procurement. That is why BRUCEHAN propose: by focusing on serving clients in the early stages of a project, our service value is maximized.

4. We believe that it is not that you are unable to complete the registration—it is simply that, before your business has made concrete progress, your judgment of the value and investment risk of completing the registration has deviated. Or perhaps there has been a delay in your home country in providing the corresponding qualifications. We emphasize once again: there is no physical offline address for GACC/CIFER registration; the only official online registration portal is: https://cifer.singlewindow.cn. For all new project clients, we recommend that you prepare your GACC/CIFER overseas manufacturer registration materials before the project begins.