120 Days After Order No. 280: Cross-Border Supplements Enter the Three-Certificate Era

What Order No. 280 Changes

The Provisions of the People’s Republic of China on the Registration and Administration of Overseas Manufacturers of Imported Food (General Administration of Customs Order No. 280) were issued on October 14, 2025, and took effect on June 1, 2026, repealing Order No. 248.

The core change is a shift from Order No. 248’s fixed catalogue and strict pre-entry review to dynamic risk grading, category-based management and end-to-end oversight. The registration system changes in three ways: high-risk categories are placed on a dynamic catalogue and require review and recommendation by the competent authority in the country of origin; low-risk categories or companies from countries covered by mutual-recognition agreements may use a simplified list-registration process; and the registration validity period remains five years, but an automatic renewal mechanism has been added. High-risk categories are placed on a list excluded from automatic renewal and must undergo a new review three to 12 months in advance.

The regulatory focus is also shifting downstream. Major changes to a company’s information require a new registration application. Customs may conduct follow-up reviews at any time through written review, video inspection or on-site inspection, and can immediately suspend imports in cases of non-compliance. If the overseas competent authority’s oversight becomes ineffective, Customs may directly suspend imports of relevant food products from that country.

Health Foods Included in the Supporting Catalogue

On March 18, 2026, the General Administration of Customs issued an announcement on the supporting catalogue. The catalogue of imported food categories requiring registration recommended by an official authority contains 17 categories: meat and meat products, casings, bird’s nest and bird’s nest products, bee products, eggs and egg products, edible oils and fats, stuffed pasta, edible grains, milled grains and malt, dehydrated vegetables, seasoning powders, nuts and seeds, dried fruit, foods for special dietary uses, health foods, dairy products and aquatic products.

The list of foods excluded from automatic renewal includes meat and meat products, as well as bird’s nest and bird’s nest products.

The filing requirements are also specific. Imported food brought in as cargo and entering the Chinese market for human consumption or use as a food-processing ingredient must have the overseas manufacturer’s registration number in China, corresponding to the country of origin, entered in the Product Qualification field of the customs declaration at the time of import. Products without a registration number may not be imported.

Why Cross-Border Trade Is Nominally Exempt but Practically Tightening

Article 30 of Order No. 280 states that food imported through cross-border e-commerce retail is handled in accordance with the relevant rules governing the supervision of cross-border e-commerce retail imports and exports. In other words, cross-border goods are not regulated as cargo but as goods for personal use and are not included in the strict general-trade registration system. The direct impact on cross-border dietary supplements is therefore limited.

That does not mean cross-border businesses can operate outside the framework. Three supporting measures create substantive constraints.

First, there is a key-ingredient list under enhanced supervision. About 20 ingredients are currently included. Products containing listed ingredients, whether imported through general trade or cross-border channels, must provide a certificate of origin and technical specifications.

Second, full-ingredient declarations and document-consistency checks are becoming mandatory. The declaration of excipients is included in the required scope, creating closed-loop control over all ingredients, including raw materials and excipients. Declaration information must fully match the registration or filing certificate, overseas formula description, third-party testing report, Chinese label and actual product. Otherwise, the goods may be returned.

Third, origin and authenticity checks are being strengthened. Platforms are expected to move from formal review to substantive verification, checking the authenticity of the production origin and compliance of product claims. Videos showing continuous offline sales overseas are a product of this approach.

Three Certificates and Mandatory Port Checks

Under this three-part framework, products containing key ingredients under enhanced supervision must have three certificates: a certificate of origin, a certificate of free sale and official evidence that the product is approved or accepted for human consumption in its country of origin.

For the bonded-warehouse inbound process, the practical experience is that every shipment faces mandatory checks at the port. Document review is more detailed, and the likelihood of manual customs-document review is increasing. The practical recommendation for businesses is to reserve more than one month of buffer time and confirm one key point with the logistics provider in advance: if the documents raise questions, will the goods be returned directly, or is there room for clarification? Establishing this in advance is more effective than asking after a problem occurs.

The Impact Is Tiered

Genuine overseas brands have a verifiable origin, overseas sales records and complete documentation. Their compliance costs will rise, but they may benefit relatively after weaker businesses exit the market. This is another side of the “year of compliance.”

Private-label brands and brands operating their own factories must provide a complete set of documents, including the factory’s business registration certificate, manufacturing agreement, customs declaration, certificate of free circulation and certificate of origin. The last two documents are now required earlier in the process. Businesses that can complete the package will remain; those that cannot will exit.

White-label businesses and brands without scaled distribution will be affected most. Once certificates of free circulation and origin are required at an earlier stage, these businesses will generally be unable to complete the documents during onboarding. The result is a sharp, market-clearing tightening.

Platforms are moving from formal review to substantive verification and from post-event handling to preventive controls. They are also required to break down data silos and establish end-to-end traceability.

What to Watch Over the Next 12 Months

Three developments warrant attention. First, the key-ingredient list under enhanced supervision may expand dynamically, making regular review mechanisms necessary. Second, Customs, market regulators and platforms are expected to connect their data, while end-to-end traceability based on a unique code for each product is advanced. Third, the direction toward the same standards, supervision and penalties for cross-border and domestically produced goods is already clear, so opportunities for regulatory arbitrage will continue to narrow.