Importing Pet Food to China: GACC Quarantine Access, MOA Registration and the 2026 Rule Change

Pet food is feed in China, not food — and that single classification decides which government approvals you need

If you take one thing from this page, take this: Chinese law does not treat pet food as food. It is classified as feed (饲料), which means the entire food-import apparatus that most overseas brands know — GACC Decree 248 overseas food manufacturer registration, food importer filing, the food track under the Food Safety Law — is the wrong door. Pet food runs on two separate tracks that sit in two different ministries, and both must be cleared before a single bag can legally be sold in China.

The clarification is not a technicality. The General Administration of Customs applies a quarantine access regime to overseas pet food and a registration regime to overseas pet food manufacturing plants, while the Ministry of Agriculture and Rural Affairs applies a product import registration regime to the product itself. Countries get access. Plants get registered. Products get certificates. Three separate gates, and a foreign brand that clears two of them still cannot ship.

The two-track structure is the reason pet food launches in China fail. Brands register the product, discover the plant is not on the GACC list, and lose a shipping season.

The three product categories — and why only two of them need MOA registration

Article 2 of the Pet Feed Administrative Measures (issued as Ministry of Agriculture and Rural Affairs Announcement No. 20 of 27 April 2018, in force 1 June 2018) defines pet feed as industrially processed products for direct consumption by pets, also called pet food, and splits it into three categories with three different compliance burdens:

| Category | Statutory definition | MOA import registration certificate required? | |---|---|---| | Pet compound feed (宠物配合饲料) | Multiple feed raw materials and additives blended to a ratio to meet nutritional needs at a life stage or physiological/pathological state; alone it satisfies the pet's full nutritional needs — this is everyday complete kibble and wet food | Yes. Required for import under Art. 14 | | Pet additive premix feed (宠物添加剂预混合饲料) | Nutritional additives — amino acids, vitamins, trace minerals, enzymes — blended with a carrier or diluent; this covers supplements and nutritional powders | Yes. Required for import under Art. 14 | | Other pet feed (其他宠物饲料) | Products formulated for rewarding a pet, interacting with it, or stimulating chewing and tearing — treats, jerky, dental chews, snack sticks | No MOA product registration. Still needs GACC quarantine access, a registered plant, a compliant Chinese label and hygiene compliance |

That third row is the most valuable line in this article, because it is the one that gets misread in both directions. Treats-only brands assume they are exempt from everything and discover the quarantine permit problem at the port. Complete-food brands assume treats follow the same rule and over-budget the registration.

What does not change across categories: Article 15 requires pet feed exported to China to be packaged with a Chinese label meeting the Pet Feed Labelling Provisions, hygiene indicators meeting the Pet Feed Hygiene Provisions, and raw materials and additives drawn from the Feed Raw Materials Catalogue and Feed Additives Catalogue. Article 4 is blunt about the consequence: it is prohibited to use any substance outside those two catalogues to produce pet feed. If a formulation contains an ingredient that is not on the Chinese catalogue — including ingredients perfectly legal in the EU or US — the product is not registrable as formulated.

Track one — GACC: country access, plant registration, importer filing, quarantine permit

The customs track is governed by the Administrative Measures for the Inspection and Quarantine Supervision of Import and Export Feed and Feed Additives — originally AQSIQ Order No. 118 of 20 July 2009, amended five times and most recently by GACC Order No. 283, published 27 April 2026, with the feed amendments in force from 1 November 2026.

Step 1 — Is your country on the access list? Article 7 requires GACC to set inspection and quarantine requirements by feed product category, conduct a risk analysis for any country exporting to China for the first time, and publish the resulting list of permitted countries and product categories. Pet food sits inside the published access list for animal and plant quarantine. If your country has no access, the process is a government-to-government exercise: the exporting country's competent authority applies to GACC, GACC issues a risk assessment questionnaire, and if the assessment passes the two sides negotiate a protocol and GACC publishes the access. A brand cannot self-nominate; the route runs through the exporting country's ministry.

Step 2 — Is your plant on the GACC register? Overseas manufacturers must be examined and found satisfactory by the competent authority of the exporting country, then recommended by that authority to GACC. GACC reviews the recommendation, decides whether to conduct an on-site抽查 based on risk, and publishes the plants it registers on its official website. Article 13 sets the registration at 5 years; renewal must be requested by the exporting country's competent authority 6 months before expiry, with GACC able to conduct a retrospective review of the exporting country's regulatory system and spot-check applicants. Plants that fail the spot check are refused, and the reason is notified back to the exporting authority.

This is a country-driven, not brand-driven, process. Your government has to recommend you. That is why the plant registration timeline is the single least controllable variable in a pet food launch.

Step 3 — Importer filing. Article 26 puts feed importers under a filing regime: the importing enterprise must file with the local customs house before or at the time of its first inspection declaration. This is a mainland-entity obligation.

Step 4 — The quarantine permit. Article 15 states that where an imported feed requires an entry animal and plant quarantine permit, it must be obtained. Under the Administrative Measures for Quarantine Approval of Entry Animals and Plants (AQSIQ Order No. 25, as amended), Article 4 requires the applicant to be a unit with independent legal-person status that signs the foreign trade contract directly, and Article 5 requires the application to be made and the permit obtained before the trade contract is signed. GACC maintains the list of products requiring approval and adjusts it dynamically — Announcement No. 77 of 2024, for example, removed quarantine approval for plant-origin feed and several other categories. Whether your specific consignment needs a permit is therefore a live check against the current list, not a fixed rule.

Customs' own service guidance shows how granular this gets: for risk level I feed, the applicant must provide evidence of the production, processing and storage unit; where pet food raw materials originate from approved establishments in a third disease-free country, a statement of raw material origin is required; and for non-single-ingredient feed, a composition statement or a label showing the detailed composition plus a declaration on whether restricted ingredients are present. Approval decisions are due within 20 working days of acceptance.

Step 5 — Declaration and inspection. Article 16 requires the owner or agent to declare to customs before or at the time of entry, providing certificate of origin, trade contract, bill of lading, invoice and, depending on the product, the exporting country's inspection and quarantine certificate.

Track two — MOA: the product import registration certificate

The agriculture track is governed by the Administrative Measures for the Registration of Imported Feed and Feed Additives, made under the Feed and Feed Additives Regulation. Article 3 is the operative prohibition: an overseas enterprise exporting feed or feed additives to China for the first time must obtain an import registration certificate, and without it the product may not be sold or used in China.

Article 4 decides who can file, and it is the clause that blocks brands without a mainland presence: registration is filed by the overseas enterprise's office resident in China, or by a Chinese domestic agency entrusted to act. For pet compound feed and pet additive premix feed, Article 14 of the Pet Feed Administrative Measures says the same thing in pet-specific terms.

The procedural clock is fixed:

1. Examination — 10 working days from acceptance (Art. 9). If the dossier passes, the applicant is told to send samples to the designated testing institution.
2. Re-testing — 3 months (Art. 10). The designated institution completes re-testing of the quality standard and the samples. Where a national or industry standard method exists it takes priority. The overseas enterprise has 15 working days from receipt of the report to request a re-check if it disputes the result (Art. 11).
3. Certificate — 10 working days after a passing re-test (Art. 12), followed by publication.
4. Validity — 5 years (Art. 14).
5. Post-certification filing — 6 months (Art. 22). The overseas enterprise must establish a sales organisation or appoint a sales agent in China and file it with the ministry within 6 months of obtaining the certificate; any change must be re-filed within 1 month.

The application dossier under Article 7 is substantial and must be submitted in Chinese and English in duplicate, together with samples: the application form; the power of attorney and the agent's qualification documents; proof that the product is approved for production and use in the country of production plus registration data from other countries and marketing history; product name, composition, physicochemical properties, scope of use and method of use; production process, quality standard, test method and test report; the label, trademark and Chinese label artwork used in the country of production; and, for microbial or fermentation products, details of strain deposition.

Two penalty provisions are worth reading before you appoint an agent. Article 29 provides that false dossiers or samples lead to rejection and a one-year freeze on applications from that overseas enterprise and its registration agent; where a certificate was obtained by deception, it is revoked, the registration agent is fined between RMB 50,000 and 100,000, and both are barred for three years.

What changes on 1 November 2026

GACC Order No. 283 re-issues the feed inspection and quarantine measures with amendments that take effect 1 November 2026. For pet food importers, four changes matter commercially:

• Business records: 2 years becomes 3 years. Article 27 now requires importers to keep records for no less than 3 years, covering the declaration number, product name, quantity/weight, packaging, exporting country or region, overseas exporter, the overseas manufacturer's name and its registration number, the entry goods inspection and quarantine certificate, and the downstream flow of the goods. Article 28 adds that customs reviews those records and tightens inspection and quarantine on the importer's feed where the review fails. Record-keeping is now a clearance-speed issue, not an admin issue.
• Labelling is tied to the national standard. Article 25 now expressly requires import feed packaging to meet Chinese safety and hygiene requirements and to carry a label conforming to China's national feed labelling standard. Feed raw materials that are imported in bulk for processing rather than direct feeding may be imported unpacked, but must still carry a compliant label and use compliant containers and transport, with no cross-mixing in transit. Where China restricts the feeding scope of an animal-origin feed, the retail package must state that scope.
• Risk grading drives the clearance path. The measures apply product risk grading and enterprise classification, with customs adopting different inspection and quarantine supervision models and adjusting them dynamically. The practical consequence is that two pet food SKUs from the same brand can face materially different inspection intensity.
• Registration validity is explicit at 5 years, with renewal through the exporting authority six months before expiry.

If you are mid-launch, the cheapest action is to extend your record-retention policy to three years now and re-check your Chinese label against the national feed labelling standard before 1 November, rather than discovering the gap at inspection.

Labels, hygiene and the catalogue problem

Chinese labelling is where otherwise-approvable pet food gets refused at the port. The Pet Feed Labelling Provisions (Annex 3 to MOA Announcement No. 20) require the label to state product name, raw material composition, guaranteed analysis values, net content, storage conditions, directions for use, precautions, production date, shelf life, manufacturer name and address, the licence document number and the product standard. The label must carry the statement "本产品符合宠物饲料卫生规定" in a prominent position and be accompanied by a product quality inspection certificate.

Generic names are regulated, not optional. Pet compound feed must use a generic name containing "宠物配合饲料", "宠物全价饲料", "全价宠物食品" or "全价", and must state the target animal species and life stage; if species is not stated it defaults to all breeds and sizes, and if life stage is not stated it defaults to all life stages. Products formulated for a specific physiological or pathological state must carry the word "处方". Pet additive premix feed must use "宠物添加剂预混合饲料", "补充性宠物食品" or "宠物营养补充剂". Other pet feed must use "宠物零食". Where a brand name is also shown, it must sit after or below the generic name and in a font no larger than it.

Two formulation-level points deserve their own line. First, the Feed Raw Materials Catalogue and Feed Additives Catalogue are closed lists — Article 4 of the Pet Feed Administrative Measures prohibits any substance outside them. Second, hygiene indicators must meet the Pet Feed Hygiene Provisions; Announcement No. 20 set 1 January 2019 as the date from which domestically produced and imported pet feed must comply.

Duty, taxes and classification

Retail-packed dog and cat food is classified in HS heading 2309. Per the 2026 Tariff Adjustment Plan's provisional duty schedule:

| HS code | Product | MFN rate | 2026 provisional rate | |---|---|---|---| | 23091010 | Retail-packed canned dog or cat food | 15% | 10% | | 23091090 | Other retail-packed dog or cat food | 15% | 10% | | 23099090 | Other prepared animal feed | 6.5% | 4% |

Import-stage VAT is charged at the applicable rate under the VAT Law, with the actual rate confirmed at declaration. Both 2309 headings carry the inspection and quarantine code for entry animal and plant products and the entry goods clearance requirement, which is the customs-side marker that the GACC track applies. Preferential rates under free trade agreements and RCEP may apply depending on origin — worth checking before you price, because the spread between MFN and agreement rates on this heading is wide.

Where foreign brands actually get stuck

The legal structure produces four predictable failure points.

1. No mainland party, no permit and no certificate. The quarantine permit requires an applicant with independent legal-person status that signs the contract directly. The MOA registration must be filed by a China office or a Chinese domestic agency. Both are hard requirements, and both sit upstream of the first shipment. A Hong Kong entity as importer of record is the standard structure that solves the first, and a contracted Chinese agency solves the second — but they must be in place before filing, because the registration certificate is issued in the name of the product and the certificate holder must then file a China sales organisation or agent within six months.

2. The ingredient list is not a Chinese ingredient list. A formulation built for EU or US compliance routinely contains something outside the Feed Raw Materials Catalogue or Feed Additives Catalogue. Reformulating after the dossier is submitted costs a full re-test cycle — three months under Article 10.

3. Country access is assumed, not verified. "We already export to China" is not the same as "our plant is on the GACC register for pet food". The register is plant-specific and product-specific, and it is maintained by recommendation from the exporting authority.

4. The 1 November 2026 transition. Importers whose records run on a two-year retention policy, or whose labels meet the Pet Feed Labelling Provisions but not the national feed labelling standard now referenced in Article 25, will meet friction at inspection rather than at registration.

For most brands the sequencing that works is: confirm country access and plant registration → lock a mainland or Hong Kong importer structure and agency → fix the formulation against the catalogues → file MOA registration for compound and premix products → prepare the Chinese label → then book production. Running channel conversations in parallel is fine; running registration after production is not.

The alternative for brands that want to test demand before committing to a registration cycle is the bonded cross-border model, which moves product for consumer orders under a different customs regime — see What Is 1210 Bonded Import? and 1210 Bonded vs Direct Mail for how that route compares. It is a demand-testing tool, not a substitute for the feed registrations once you intend to trade through domestic channels.

Sources

• Pet Feed Administrative Measures, Pet Feed Labelling Provisions and Pet Feed Hygiene Provisions — Ministry of Agriculture and Rural Affairs Announcement No. 20 (27 April 2018, in force 1 June 2018) — MOA
• Pet Feed Labelling Provisions (Annex 3 to MOA Announcement No. 20) — full text — MOA
• Pet Feed Administrative Measures — full text, Arts. 2, 4, 14, 15 — MOA
• Administrative Measures for the Registration of Imported Feed and Feed Additives — Arts. 3, 4, 7, 9, 10, 12, 14, 22, 29 — MOA
• 同上 — State Council Gazette version, Arts. 22–30 (recall, penalties) — State Council Gazette
• GACC Order No. 283, Decision on Amending Certain Rules (published 27 April 2026; feed measures amendments in force 1 November 2026) — State Council Gazette full text — State Council Gazette
• GACC Order No. 283 — Decision on Amending Certain Rules (PDF, customs.gov.cn) — GACC
• Administrative Measures for the Inspection and Quarantine Supervision of Import and Export Feed and Feed Additives (AQSIQ Order No. 118, as amended through GACC Order No. 262) — GACC
• Administrative Measures for Quarantine Approval of Entry Animals and Plants (AQSIQ Order No. 25, as amended) — Arts. 2, 4, 5 — GACC
• Customs administrative licensing service guide — quarantine approval for animal and animal-derived products; risk level I feed documentation, pet food raw material origin statements, 20-working-day decision — Guangzhou Customs
• Quarantine approval service guide for entry plants and plant products — feed and feed additives must come from published access lists — Shenzhen Customs
• GACC Announcement No. 77 of 2024 — removal of quarantine approval for plant-origin feed and other categories, with the approval list subject to dynamic adjustment — GACC / Ministry of Commerce
• Quarantine access list for entry animal and plant products (动植物检疫准入名单) — GACC
• Importing pet food: quarantine access and registration — Ningbo Customs explains the six-step GACC process and the MOA import registration regime — People's Daily / Ningbo Customs
• 2026 Tariff Adjustment Plan — provisional import duty schedule, HS 23091010 / 23091090 / 23099090 — State Council Tariff Commission

Related reading

• Do You Need GACC Registration to Import Food Into China?
• GACC Food Registration: The Process Step by Step
• Which Chinese Agency Regulates My Product?
• China Market Entry Roadmap for Pet Brands
• Hong Kong Entity for China Import
• Importing Into China Without a Local Company
• China Import Product Labelling Requirements
• China Import Taxes and Landed Cost
• HS Code Classification for Importers
• What Is 1210 Bonded Import?
• Bonded Warehouse & Customs