Exporting Food and Cosmetics to China: Four Steps

Step 1: Is the product exportable?

Start with the Harmonized System (HS) code.

• Look up the product’s HS code.
• Take the first four digits, that identifies the product group.
• Use it to check customs data: is the product being imported into China, in what volumes, and from which countries?

Not everything is in demand. Toys and rubber balls are rarely imported; chocolate, biscuits and vegetable oil are. Finding that out from customs data costs nothing; finding it out after certification costs everything spent on it.

Step 2: Register the trademark

To protect the brand and sell legally on Chinese marketplaces, register the trademark in China. Without it, third parties can register your brand name and you cannot list on JD, Taobao or Tmall.

Twelve months is the number that shapes the plan. A trademark started at the same time as the export project will not be registered when the first container is ready.

Step 3: Register in the Cypher system

Since 1 January 2022, all food producers exporting to China must register with the Cypher system, under GACC Decrees No. 248 and 249.

• It is the official registry managed by China’s General Administration of Customs.
• Only manufacturers are eligible. Distributors cannot register.
• Each production site receives its own Cypher ID.
• That ID must be printed on a Chinese-language label; without it, customs clearance is impossible.

Two registration types

To apply you need the company tax ID, the product list with the first four digits of each HS code, and the number of production sites.

Step 4: What must the Chinese counter-label show?

All imported products need a Chinese-language counter-label carrying:

• Product name
• Cypher number
• Manufacturer
• Shelf life
• Ingredients
• Importer in China

Without this label the product will not pass customs.

Common mistakes

• Cypher applies to manufacturers only. A distributor cannot register on a producer’s behalf.
• No trademark means a real risk of brand hijacking, and no marketplace listing.
• Marketing before documents is wasted. Without Cypher and a trademark, customs blocks entry regardless of demand generated.
• Supplements and pharmaceuticals need separate, costly certifications that this route does not cover.

Sources

• GACC Decrees No. 248 and No. 249, registration of overseas food producers
• China National Intellectual Property Administration (CNIPA), trademark registration
• Madrid System for the International Registration of Marks, WIPO