Take home
- The CBEC transition period has been officially granted according to China GAC, which will end on May 11th 2017.
- During the grace period, CBEC commodities don’t need to obtain the “Customs Clearance of Entry Commodity” (CCEC). Cosmetics, infant formula, medical device, special foods (such as health food and food for special medical purposes) can still be imported via CBEC without pre-market approval by CFDA.
On 25 May 2016, China GAC released a notice specifying new supervision requirements for CBEC retail imports. Under the new announcement CBEC stakeholders have been given a “green light” until 11 May 2017 for their products. Within the buffer period it will be business as usual except for the implementation of the new tax policy and positive list. Import procedures will remain the same as before which forgo complicated application documents for CIQ inspection, Chinese labels, pre-market approval documents, etc.
For CBEC bonded warehouse mode:
During the time, pilot cities (including Shanghai, Hangzhou, Ningbo, Zhengzhou, Guangzhou, Shenzheng, Chongqing, Tianjin, Fuzhou and Pingtan) will continue to supervise CBEC imports like before. Specifically, CBEC products are not required to have the CCEC for market entry. Unregistered cosmetic products, infant formula, medical device, health foods and medical foods can still enter China through the CBEC channel.
For CBEC direct shipping mode:
The CCEC is not needed and pre-market approvals for the above products falling under the registration system are not required as well.
It’s a great relief for general commodities who have more time to adjust product portfolios and prepare for upcoming restrictions next year. For CBEC platforms with cosmetics, baby products (especially infant formula) and health foods as featured products, one year may not be enough to fulfill product registration. Exporters are highly recommended to find a trustful Chinese consultant who could provide professional advice to help in product compliance.