Every food or beverage brand we meet at Ecommerce China Agency asks the same question in different words: what do we actually need to be legal in China? The honest answer is that Chinese food regulation is not one system. It is two parallel systems, general trade import and cross-border e-commerce (CBEC), each with its own paperwork, its own timeline, and its own risk profile. Brands that mix the two up waste months and sometimes lose entire shipments at customs.
This guide sets out the rules that matter in practice: GACC overseas facility registration, the GB 7718 and GB 28050 labelling standards, the positive list for CBEC food, and the strict line China draws between ordinary food and products allowed to make a health claim. We finish with the sequencing most brands actually use to get to market without drowning in compliance costs before they have sold a single unit.
GACC overseas facility registration: the first gate
The General Administration of Customs China (GACC) requires that any overseas facility producing, processing, or storing food destined for the Chinese market be registered before that food clears customs. This came out of Decree 248, which took effect in 2022, and it applies at the facility level, not the brand level. If your product is made in three different plants, all three need registration, or you need to be honest about which plant is actually shipping to China.
For most categories, registration is self-declared through the competent authority in the country of origin, which forwards the application to GACC’s CIFER system. High-risk categories, meat, dairy, seafood, edible oils among others, require recommendation by the exporting country’s government first. Either way, the registration number needs to appear on the outer packaging and in the customs declaration. Miss it, and the container sits at the port.
What is changing now matters. Customs Regulation No. 280, published in October 2025 and taking effect on 1 June 2026, extends a similar registration obligation to foreign producers supplying health products through cross-border channels, previously the CBEC personal-use route offered lighter treatment here. From that date, import declarations for the affected categories must carry a valid registration number from the foreign producer, and declarations without one will not be accepted. Brands relying on CBEC as a shortcut around facility registration need to check whether their specific product category is caught by this update well before the deadline.
GB 7718 and GB 28050: the labelling backbone
GB 7718 is China’s general standard for pre-packaged food labelling. It sets out what has to appear on a Chinese-language label: product name, ingredient list in descending order of weight, net content, producer and importer details, production date and shelf life, storage conditions, and the food production licence number where relevant. Allergen declarations are expected in practice even where not always strictly mandatory, and brands that skip them tend to get flagged during customs sampling.
GB 28050 covers nutrition labelling specifically. It requires a nutrition facts panel (营养成分表) showing energy, protein, fat, carbohydrate, and sodium as a minimum, with values expressed both per 100g/100ml and per serving. A recent revision tightened rounding rules and added requirements for labelling saturated fat and sugar content on more product categories, part of a broader public health push that has been building since 2023. Brands that translate their home-market label rather than rebuilding it against GB 28050 from scratch almost always fail on this point, because the format, the reference values (NRV%), and even the units differ from US or EU conventions.
Labels also need pre-approval or at minimum a compliance check before the first shipment. This is not optional paperwork. Chinese customs and market regulators actively spot-check labels after entry, and a non-compliant label can trigger a product recall even after goods have reached the shelf or the warehouse.
Domestic import versus cross-border e-commerce: two different games
The domestic general trade route treats your product as a Chinese product from the moment it clears customs. It needs full compliance with GB 7718 and GB 28050 on a Chinese label affixed before entry, it needs a Chinese import food registration filing, and depending on the category it may need product-specific certificates or even China Compulsory Certification. Once cleared, it can be sold anywhere in the country through any channel, with no restriction on order size or delivery method.
CBEC retail import is a different legal fiction entirely. Goods are treated as personal purchases made by an individual consumer, shipped through bonded warehouses in free trade zones such as Hangzhou, Zhengzhou, or Ningbo, or as direct mail parcels. Because the buyer is legally the end consumer rather than a domestic importer, CBEC does not require full Chinese labelling before the sale, a compliant English label with a supplementary electronic or sticker translation is often enough, and it skips the food registration filing that general trade requires. Import duty is replaced by a simplified cross-border tax, and each individual buyer faces an annual purchase limit, currently RMB 26,000 per year with a RMB 5,000 single-transaction cap in most pilot zones.
The tradeoff is real. CBEC is faster to launch and cheaper in upfront compliance cost, but every SKU has to sit on the CBEC positive list, sales only happen through approved cross-border platforms and bonded zones, and volume is capped by both the personal purchase limits and by how much stock a brand is willing to pre-position in a bonded warehouse. Brands treating CBEC as a permanent strategy rather than a market-entry step often hit a ceiling they did not plan for.
Selling through Tmall Global is the most common way brands access the CBEC route, since it operates as a cross-border platform by design and handles much of the bonded warehouse logistics for merchants that meet its onboarding requirements.
The positive list: no list, no sale
The CBEC positive list, formally the Cross-Border E-Commerce Retail Import Commodity List, is a tax-code-level catalogue of product categories eligible for the simplified CBEC route. If your product’s HS code and category are not on the list, it cannot legally move through cross-border channels regardless of how good your labelling or documentation is. The list is periodically expanded, the most recent round pushed the total past 1,470 tax items and added categories like certain sports and household goods, alongside continued tightening on endangered species and environmental compliance for food-adjacent products.
Checking positive list eligibility should be step one, before a brand invests in translation, packaging redesign, or platform onboarding. We have seen brands build an entire launch plan around Tmall Global only to discover their specific product formulation, often a supplement blend or a novel ingredient, sits outside the current list. At that point domestic registration becomes the only route, with all the extra time that entails.
Health claims: the line most brands cross by accident
China draws a hard line between ordinary food (普通食品) and registered health food (保健食品), the latter identified by the small blue hat logo (蓝帽子) on approved packaging. Ordinary food, including CBEC food products, cannot claim to prevent, treat, or cure any condition, cannot claim a specific physiological function such as boosting immunity or improving sleep, and cannot use suggestive terms like “clinically proven” or “medical grade” on packaging or marketing copy.
Only products that have gone through Blue Hat registration, or the lighter-touch filing process for a narrower set of nutrient categories, are permitted to state a specific health function. That process is slow, often twelve to eighteen months, and expensive, running into hundreds of thousands of RMB once testing and dossier preparation are included. It is a real barrier, and it is the reason so many supplement and functional food brands enter China as an “ordinary food” first and adjust their marketing language accordingly rather than waiting years for Blue Hat approval before selling anything.
This restriction catches out marketing teams more than logistics teams. A perfectly compliant shipment can still get a store flagged or a listing pulled because the product description on the storefront used language reserved for registered health food. Platform content review and market supervision authorities both check for this, and enforcement has become noticeably stricter since 2023.
Solutions: how brands actually sequence this
Very few brands go straight to domestic general trade registration on day one, and we generally advise against it. The sequencing that works for most of our clients looks like this.
Start with CBEC. Confirm the product sits on the positive list, build a compliant bilingual label that satisfies platform requirements even though full GB 7718 conversion is not mandatory at this stage, and launch through a bonded warehouse partner or a cross-border platform storefront. This validates demand with real Chinese consumers at a fraction of the cost and time of full registration, and it lets a brand test pricing, positioning, and which SKUs actually move before committing further.
Once volume and repeat purchase data justify the investment, typically once a brand is bumping against the annual personal purchase limits at scale or wants to sell through general retail and offline channels, move the best-performing SKUs through full GACC facility registration and GB 7718/GB 28050 compliant labelling for general trade. This opens up domestic marketplaces, offline retail, and removes the CBEC purchase caps entirely. Running both channels in parallel for a transition period, CBEC for trial SKUs and new launches, general trade for proven bestsellers, is the pattern we see working best in practice.
Throughout, distribution partners matter as much as the paperwork. A good importer of record or distributor already holds the licences, has existing GACC-registered relationships, and can absorb some of the registration burden rather than a brand building all of this from zero. Our guide on how to find distributors in China covers how to vet partners for exactly this kind of regulatory capability, not just sales reach.
None of this is static. The June 2026 extension of registration requirements into parts of the CBEC health product supply chain is a reminder that the “light touch” route gets less light over time as Chinese regulators close gaps between the two systems. Brands that build compliance into their launch plan from the start, rather than treating it as an afterthought once a shipment gets stuck, tend to move faster once the rules tighten.
Food and beverage remains one of the more heavily regulated categories for cross-border sellers in China, but it is also one of the categories where consumer demand for imported quality and safety is strongest. Our food and beverage sector page sets out how we help brands navigate registration, labelling, and channel strategy together rather than as separate problems handled by separate consultants.
Sources: General Administration of Customs of China, GACC policy bulletin on Regulation No. 280 and overseas facility registration (customs.gov.cn, April 2026); CIRS Group regulatory briefing on Decree 280 supporting documents and the recommended registration catalogue for cross-border retail imports (cirs-group.com); Shanghai Cross-Border E-Commerce Association overview of the cross-border retail import commodity list system (scea.co).
Matt Sun is Chief Ecommerce Officer at Ecommerce China Agency, where he leads the firm’s food and beverage practice. He has spent the past eight years walking brands through the exact fork this article describes, most recently helping a European olive oil producer move from a CBEC pilot on Tmall Global to full GACC registration within fourteen months once repeat purchase rates confirmed the Chinese market was worth the investment. He still keeps a spreadsheet of every positive list update since 2021, because clients ask about it more often than anything else. If your team is trying to work out which route fits your product and your timeline, get in touch with our team for a straight answer before you commit to either path.
