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Food and drink

Food, drink, supplements and food-contact equipment: which registration a market requires, and what the label has to carry.

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Food, drink, dietary supplements and the equipment that processes them reach a market on the strength of a registration and a label. Laboratory testing matters, and it is rarely the thing that stops a shipment. In the Eurasian Economic Union a product carries either a Declaration of Conformity or a State Registration Certificate, and which one applies is fixed by the product rather than by preference: baby food, medical dietary products, sports nutrition, dietary supplements and mineral water above 1 mg/dm3 take state registration under TR CU 021/2011, while the rest of the food list declares.

In most of these markets the producer is registered before the product is. Since 1 January 2022, under GACC Decrees No. 248 and 249, every food manufacturer exporting to China holds a Cypher ID issued per production site, and distributors cannot hold one at all. India issues the FSSAI import licence only to a company registered in India, then wants a No Objection Certificate for each consignment through the Food Import Clearance System. Morocco rejects dossiers filed without a Moroccan legal entity or a regulatory representative, and the UAE runs everything through the MOIAT platform under a named applicant.

The label is where compliant goods get stopped. A Chinese counter-label has to carry the Cypher number, the manufacturer, the shelf life and the importer in China, or customs refuses the consignment whatever else is in order. Israel treats Hebrew labelling as a condition of sale rather than a courtesy. Morocco requires French and Arabic with medical claims such as heals or treats removed, because wording that reads as ordinary marketing elsewhere reclassifies the product as a pharmaceutical there. TR CU 022/2011 sets the equivalent content list behind the EAC mark.

Two further problems recur across these articles. Religious certification is settled by who issued it: GCC importers accept halal certificates only from bodies recognised by ESMA, the Saudi Food and Drug Authority or the GCC Accreditation Center, and a foreign kosher certificate is not automatically recognised by the Chief Rabbinate of Israel. Then there is the plant, since process equipment for food, meat, dairy and fish is declared under TR CU 010/2011, with TR CU 004 and TR CU 020 added where it is low-voltage. Send us the product and the destination and we will name the route.

18 articles in Food

Frequently asked questions

Do I register the company or the product first?

The company, almost everywhere in this section. A Cypher ID in the GACC system is issued to a production site before any consignment moves, the FSSAI import licence has to sit with an Indian entity before a consignment NOC can be requested, and a Moroccan dossier without a local representative is refused rather than corrected. Product work done ahead of the establishment registration usually has to be repeated.

How much time should a launch schedule allow?

More than the certificate fee suggests. A complete supplement dossier in Morocco runs up to four months against the two to three weeks manufacturers commonly budget, Israel wants three to six months because sanitary and religious inspections both have to happen, a Chinese trademark takes roughly twelve months to full registration, and a first retail consignment into China opens a border registration dossier that adds 10 to 15 business days.

Tell us what you are exporting

Send the product name, HS code and technical data. You get back the applicable route, the document list and a timeline, before any commitment.

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