1. Two registrations, not one
Fishmeal is classified as a "single feed" (单一饲料) under Chinese regulations. Feed-grade fishmeal for China typically requires two separate compliance tracks, administered by two different Chinese government agencies:
GACC — General Administration of Customs
Registers your production facility. Managed through the DAPQ (Department of Animal and Plant Quarantine) system. Without GACC facility registration, your fishmeal faces a high risk of being blocked at Chinese ports.
MARA — Ministry of Agriculture and Rural Affairs
Registers your product. Issues the Import Registration Certificate (进口登记证). Without MARA product registration, your fishmeal cannot be commercially distributed or used in China, even if it passes customs inspection.
Both registrations are mandatory. Both are valid for 5 years. Both should be in place before your first shipment departs. Missing either one creates a high risk of hold, refusal, return, or inability to commercialize the product in China.
2. GACC facility registration (DAPQ system)
GACC maintains an approved list of countries permitted to export feed ingredients to China. Within each approved country, individual production facilities are registered through the exporting country's competent authority.
How it works
Your national competent authority (for example, EIC in India, MFD and the relevant federal authority in Pakistan, DALRRD in South Africa) reviews your facility and submits a registration dossier to GACC on your behalf. For DAPQ-listed feed products, facility registration is handled through this government-to-government channel, not through the CIFER self-registration route used for some food categories.[1]
GACC reviews the dossier, may request a questionnaire or supplementary information, and in some cases sends inspectors for on-site verification. Approved facilities are published on the GACC official list and assigned a registration number that must appear on all export documentation and product packaging.
Key requirements
| Requirement | Details |
|---|---|
| Country access | Your country must have documented feed-export access to China. Multiple countries across Asia, Latin America, Africa, and Europe have operational pathways — verify current country/product access with GACC or your competent authority.[2] |
| Competent authority submission | Individual facility dossier submitted by your national authority to GACC. |
| Facility standards | Must meet national standards AND equivalent Chinese requirements (HACCP, traceability, recall capability). |
| Registration validity | 5 years. Must be renewed before expiry.[3] |
| Timeline | Typical practical timeline: 3–12 months, depending on GACC review queue and competent authority responsiveness. |
3. MARA Import Registration Certificate
MARA registration is a product-level requirement, separate from the GACC facility registration. For feed products exported to China for the first time, overseas producers typically need to obtain a MARA Import Registration Certificate — though some product categories may qualify for waiver or exemption.[3] For fishmeal specifically, confirm with your Chinese agent whether your product requires a full MARA import registration license or qualifies for simplified treatment. Do not ship until MARA status is confirmed in writing.
How it works
The overseas producer typically appoints a registered domestic agent or subsidiary in China to submit the MARA application. The Chinese agent prepares and submits the application, which includes product specifications, laboratory test reports, label drafts, and manufacturing process documentation.[5]
MARA reviews the application and issues the Import Registration Certificate (进口登记证) if requirements are met. The certificate must be obtained before the first shipment departs — not upon arrival.
Key requirements
| Requirement | Details |
|---|---|
| Chinese domestic agent | Required in practice — typically a registered and licensed entity or subsidiary in China. |
| Product documentation | Full product specs, COA, manufacturing process, quality standards, label in Chinese (per GB 10648). |
| Laboratory testing | Product must meet GB/T 19164 (quality) and GB 13078 (hygiene) parameters. |
| Label compliance | Chinese-language label per GB 10648. Should include guaranteed analysis values, GACC registration number, and relevant quality indicators. Confirm specific label requirements with your Chinese agent. |
| Registration validity | 5 years. Renewal application must be submitted 6 months before expiry.[3] |
| Timeline | Typical practical timeline: 4–8 months from application to certificate issuance. |
4. Side-by-side comparison
| Attribute | GACC (facility) | MARA (product) |
|---|---|---|
| What is registered | Production facility / plant | Product (fishmeal as "single feed") |
| Who applies | Competent authority of exporting country | Chinese domestic agent on behalf of producer |
| Can producer apply directly? | No | No |
| Legal basis | GACC feed import quarantine regulations | MARA Decree No. 2 (2014), State Council Order 609 |
| Output | Facility listed on GACC approved list + registration number | Import Registration Certificate (进口登记证) |
| Validity | 5 years | 5 years (renew 6 months before expiry) |
| Cost estimate | Varies by country (mostly government fees) | ~$3,000–$8,000 (market estimate: agent + testing) |
| Typical timeline | 3–12 months (practical estimate) | 4–8 months (practical estimate) |
| Can run in parallel? | Yes — recommended to start both simultaneously | |
5. Why the food path is wrong for fishmeal
The most common mistake fishmeal exporters make is applying through the CIFER/Decree 248 food registration system instead of the GACC/DAPQ feed facility registration. This happens because some consultants and online guides describe all "aquatic products" under the Decree 248 umbrella — which applies to seafood for human consumption, not feed ingredients.
The key distinction: Decree 248 (and its replacement, Decree 280, effective June 1, 2026) governs overseas producers of imported food. Feed-grade fishmeal follows the feed pathway, not the imported food pathway. These are separate regulatory tracks with different legal bases, application portals, and review teams.[6]
Applying through the wrong system wastes 6–12 months and produces a registration that is unusable for feed-grade fishmeal exports. The two systems have different legal bases, different application portals, different review teams, and different documentation requirements.
6. Top 7 reasons fishmeal shipments get rejected
1. Facility name mismatch
The facility name on the GACC registration, health certificate, commercial invoice, and bill of lading should be identical. Even an abbreviated name or different legal suffix can trigger a hold. Verify exact alignment before every shipment.
2. Missing MARA certificate
GACC facility registration alone is not sufficient. Without confirmed MARA product registration status, the product faces a high risk of being held, returned, or blocked from commercial distribution in China.
3. Wrong registration pathway
Applying through CIFER (food) instead of DAPQ (feed) produces an unusable registration. Months lost, fees wasted.
4. Incomplete or non-compliant labels
Chinese feed labels must comply with GB 10648, be in Chinese, and include: product name, raw material composition, guaranteed analysis values, net weight, production date, shelf life, storage conditions, manufacturer details, and GACC registration number. Additional quality indicators (such as TVN/volatile basic nitrogen) may be required depending on product category — confirm exact label content requirements with your Chinese agent before printing.
5. COA does not cover required parameters
A COA that only covers protein and moisture is insufficient. Chinese inspection requires full coverage of GB/T 19164 (quality) and GB 13078 (hygiene) parameters including heavy metals, pesticide residues, and microbiological safety.
6. Data mismatch between registration and shipment documents
Any discrepancy between the information in the GACC/DAPQ registration and the actual shipment documentation — product name, facility address, product category — can cause holds and refusals at Chinese ports.
7. Country does not have feed-export access to China
If your country has not completed the GACC risk assessment for feed ingredients, no facility registration is possible. Verify your country's current access status before investing in registration.
7. Correct sequence: step by step
| Step | Action | Responsible party | Typical timeline* |
|---|---|---|---|
| 1 | Confirm country has documented feed-export access to China | Producer | 1 day |
| 2 | Contact national competent authority for GACC facility registration | Producer + competent authority | Week 1 |
| 3 | Engage Chinese domestic agent for MARA registration (start in parallel) | Producer + Chinese agent | Week 1–2 |
| 4 | Prepare facility dossier for GACC submission | Competent authority | Months 1–3 |
| 5 | Prepare MARA application (specs, COA, labels, process docs) | Chinese agent | Months 1–3 |
| 6 | GACC review + possible on-site inspection | GACC | Months 3–12 |
| 7 | MARA review + certificate issuance | MARA | Months 4–8 |
| 8 | Both registrations confirmed → prepare first shipment | Producer + buyer | Month 8–12 |
* Timelines are practical market estimates based on industry experience, not regulatory guarantees. Actual duration varies by country, product, and agency workload.
8. Next steps
If your facility is already GACC-registered and holds confirmed MARA product registration status, you are ready to supply the Chinese market. If you are in the process of obtaining either registration, early engagement with qualified buyers helps align your timeline with market demand.
Related guides:
→ How to Export Feed-Grade Fishmeal to China: Complete Compliance Guide
→ India fishmeal to China: EIC protocol, GACC & MARA compliance
→ Pakistan fishmeal to China: tariff edge, registration & export hubs
Related documents:
→ Remeta Fishmeal Specification PDF
→ Remeta Fishmeal Export Checklist 2026 PDF
References and sources
- [1] USDA FAS CH2024-0039 — core primary source on GACC and MARA roles, Feed Ingredients Catalog treatment, import registration licenses, and China-based agent requirements. Confirms DAPQ facility registration is handled through competent authority / government channel.
- [2] USDA FAS CH2025-0061 — export certificate framework confirming that China only allows imports of feed and feed additives from registered foreign facilities.
- [3] MARA Decree No. 2 of 2014 (Administrative Measures for the Registration of Imported Feed and Feed Additives) and State Council Order 609 — legal basis for MARA product registration. Both GACC and MARA registrations are valid for 5 years per published regulations.
- [4] USDA FAS CH2025-0204 — confirms Decree 280 (effective June 1, 2026) replaces Decree 248 for overseas producers of imported food. Does not govern feed-grade fishmeal.
- [5] China Feed Label Standard (GB 10648) — scope and mandatory feed-label structure for imported feed ingredients.
- [6] Chinese standards referenced: GB/T 19164-2021 (fishmeal product quality), GB 13078-2017 (feed hygiene). Use the latest official text or licensed standard database for final regulatory confirmation.
- Supplementary explanatory sources (used for practical process description, not as primary legal support): REACH24H, CIRS Group, Engormix.
- Timelines, cost estimates, and operational details are practical market ranges, not regulatory guarantees.
- Latest lot-specific COA
- Processing method (steam-dried / other)
- Plant location, country, and port of loading
- Current China registration status (if any)
- Indicative monthly volume and FOB basis
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Send offer via WhatsApp →9. Frequently asked questions
Do fishmeal exporters really need both GACC and MARA compliance?
In practice, yes. GACC handles facility-side access and registration; MARA handles product-side registration and licensing. Both tracks should be confirmed before first shipment. Do not assume that one approval alone is enough.
Is Decree 248 / Decree 280 relevant for fishmeal?
Only as background context. Decree 248 (and its replacement, Decree 280, effective June 2026) governs overseas producers of imported food. Feed-grade fishmeal follows the separate GACC/DAPQ + MARA feed pathway, not the imported food pathway.
How long does the full registration process take?
Typical practical timeline: 6–18 months total if GACC and MARA tracks run in parallel. Running them sequentially can extend this to 12–24 months. Start both tracks as early as possible.