25 July 2026 | Shanghai, China
For pre-packed food exporters entering Asia, facility registration responsibilities vary by market: most countries place the burden on the importer, but China's GACC Decree 248/249 requires the overseas manufacturer to register before any shipment can clear customs. Once registered, ensuring your product labels meet food label requirements for China is the next critical step.
Pre‑Packed Foods Facility Registration Audit for Multiple Asian Markets
For exporters of pre-packed foods, entering the Asian market requires more than a great product. Each country has its own facility registration requirements, and failing to comply can mean delayed shipments, rejected containers, or lost market access.
Understanding who is responsible — the exporter, the manufacturer, or the importer — is the first step toward a smooth market entry.
Facility Registration Requirements by Countries
| Country | Authority | Registration | Responsibility |
| China | GACC | Decree 248 / 249 | Manufacturer + Importer — overseas manufacturer must register first; 18 high-risk categories need recommendation from the local competent authority |
| Japan | MHLW | Import Notification | Importer — notifies each shipment; no pre-registration of foreign facilities |
| South Korea | MFDS | Foreign Food Facility Registration | Importer — registers on behalf of the overseas manufacturer; some categories require inspection |
| Vietnam | MOH / MARD | Product-by-Product Registration | Importer or Manufacturer — products and facilities must be registered |
| Thailand | FDA | Food Import Registration | Importer — registers with FDA; GMP certificate may be required from the manufacturer |
| Indonesia | BPOM | Import Registration | Importer — via a local agent; the manufacturer's facility forms part of product registration |
| Philippines | FDA | Certificate of Product Registration (CPR) | Importer — must register; manufacturer provides GMP evidence |
| Malaysia | MOH | Import Registration | Importer — provides health certificates, analysis, and GMP/HACCP evidence from the manufacturer |
| Singapore | SFA | Importer Licensing & Accreditation | Importer — licensed by SFA; certain product facilities require SFA accreditation |
All of the above rows apply to pre-packed foods.
Who Bears the Registration Burden?
In most Asian markets, the legal responsibility falls on the importer — as in Japan, Thailand, the Philippines, and Singapore. The manufacturer's role is to provide supporting documentation: health certificates, GMP evidence, product specifications, and facility registration numbers.
China is the major exception. Under GACC Decree 248/249, the overseas manufacturer must register with GACC before any product can be exported to China. The Chinese importer registers separately. For 18 high-risk categories, the manufacturer's registration must be recommended by the competent authority in the country of origin. Without this registration, shipments will not clear customs. Vietnam's dual-track access system under Decree 15/2018/ND-CP splits products into self-declaration and full registration tracks
South Korea and Indonesia also require active manufacturer involvement — the facility registration is technically required of the overseas manufacturer, though often managed by the importer or a local agent.
Pre-Packed Foods in the Chinese Market
For pre-packed food manufacturers, China's GACC registration is the most critical requirement. All overseas manufacturers must register before exporting.
Pre-packed foods generally fall under the non-high-risk track, meaning manufacturers can register directly without a government recommendation. However, accurate Chinese label translation and compliance with GB standards remain mandatory.
Why a Multi-Country Audit Matters
A facility registration audit helps manufacturers and exporters:
- Clarify responsibility — know what the manufacturer must do versus what the importer handles.
- Avoid delays — prepare documents in advance, not at the port.
- Reduce costs — avoid penalties and shipment rejections.
- Expand efficiently — enter multiple markets with confidence.
Takeaway
For pre-packed food exporters, understanding each country's registration requirements — and the responsibility split — is essential. Most Asian markets place the burden on importers, but China's GACC regime demands active manufacturer registration. A multi-country audit ensures you are prepared before you ship.
Preparing to export food to China? Read our article regarding Food Facility Registration for Overseas Manufacturers.
About Shanghai Specit Management Consulting Co Ltd
We help food and beverage brands enter and grow in the Chinese and wider Asian markets through trade intelligence, importer identification, and market research.
Disclaimer: This article is for general guidance only. Registration requirements change over time and vary by product category. Always confirm current requirements with the relevant national authority or a qualified regulatory consultant before shipping.
Related: GACC Decree 280: Two Months of Rejection Data — What Exporters Must Fix
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