AQSIQ Introduces Facilitation Measures for CBEC Customs Clearance

Takehome

AQSIQ’s first definitive statement on CBEC trade is likely designed to foreshadow upcoming requirements that all CBEC goods will be subject to standard regulatory compliance requirements.

Since the release of China’s CBEC positive lists, CBEC stakeholders have been at the mercy of China’s regulators who have vacillated from pronouncements of extremely stringent regulation to announcements of extended grace periods that essentially amounted to a “business as usual” greenlight from authorities to CBEC traders.

The ambiguous wording of many of the recent announcements exemplified by an announcement that all CBEC goods would require a CCEC (Customs clearance of entry commodity), and the lack of a cohesive voice among the cacophony of ministry pronouncement has only fueled the fire of speculation that has investors, traders and consumers scratching their heads and waiting with bated breath for a definitive statement on these issues. 

The CCEC is needed for goods in the Catalogue of Import and Export Commodities Subject to Mandatory Inspection and Quarantine. During general trade customs procedures, to obtain a CCEC, importers or its agent should apply for inspection to CIQ by submitting dossiers like packing lists, invoice, bill of lading, country of origin, sanitary certificate, test report, certificate of free sale, Chinese label, etc.Products that fall under the pre-market approval system such as health food, medical food and cosmetics require additional approval documents. If everything is verified, CIQ issues the CCEC to the applicant for customs clearance. If CBEC commodities also need to meet these requirements, obtaining this document would be a great obstacle for a number of CBEC traders.

On 15 May 2016, AQSIQ issued an explanation of the CCEC for CBEC commodities. It specifies that CBEC commodities are goods instead of personal articles which need to obtain the CCEC. AQSIQ further stated that only 36% of goods in the positive list are included in the above catalogue which require the CCEC while the rest don’t. In addition, only CBEC bonded imports are required to obtain a CCEC. CBEC direct imports are exempt from getting the document.  

Meanwhile, AQSIQ has introduced several facilitation measures to increase the efficiency of clearance of CBEC commodities:

• The CCEC will be issued when goods enter the warehouses instead of being issued package by package, to reduce the clearance time;
• The CCEC information will be available online to further improve the clearance efficiency;

The one year grace period is still hanging in the balance. However whether the policy is implemented or not, unregistered cosmetics, health foods and foods for special medical purposes dealers should initiate their product registration as soon as possible. Since the criteria for applying the CCEC is still uncertain, stakeholders are recommended to check the requirements with the actual importing port according to the specific products and wait for further moves by authorities.