Regulations and standards for China’s cold chain food exports (FDA, EU, HACCP, etc.)

I. Regulations for cold chain food imports in major international markets
China’s cold chain food exports must comply with the food safety regulations of the target market, mainly including the United States (FDA), the European Union (EU), Japan, Southeast Asia and other different standard systems.

1. US market: FDA regulations
   Applicable products: aquatic products, meat, dairy products, quick-frozen foods, etc.
   Core requirements:

“Food Safety Modernization Act” (FSMA): requires companies to establish a preventive control system to ensure food safety.

HACCP (Hazard Analysis and Critical Control Points): Mandatory for aquatic products, fruit juice, low-acid canned foods, etc.

Temperature control standards:

Frozen food: ≤-18℃

Refrigerated food: ≤4℃ (some products such as dairy products have stricter requirements)

Registration requirements: Exporters must register with the FDA and accept irregular inspections.

Label specifications: Nutritional information, allergens, origin, etc. must be marked.

2. EU market: EU regulations
   Applicable products: aquatic products, meat, dairy products, fruits and vegetables, etc.
   Core regulations:
   (EC) No 178/2002: EU basic law on food safety, requiring traceability.
   (EC) No 852/2004: Food hygiene regulations, requiring companies to implement the HACCP system.
   (EC) No 853/2004: Special hygiene regulations for animal-derived foods.
   Temperature requirements:
   Frozen food: ≤-18℃ (temporary temperature rise to -15℃ is allowed during transportation)
   Perishable food: ≤4℃
   Import license: Some high-risk products (such as meat) require a list of companies approved by the EU.
   Traceability: A full chain record from production to export must be provided.
3. Japanese market: JAS and positive list system
   Applicable products: aquatic products, meat, quick-frozen vegetables, etc.
   Core regulations:
   Food Sanitation Law: requires companies to comply with HACCP or equivalent management systems.
   Positive list system: strictly limit pesticide and veterinary drug residues, and some Chinese products need additional testing.

Temperature standards:

Frozen food: ≤-18℃

Refrigerated food: ≤10℃ (some products such as fresh require ≤4℃)

Import inspection: some Chinese products (such as shellfish and eel) need to be tested batch by batch.

4. Southeast Asian market (ASEAN)

Applicable products: aquatic products, fruits, quick-frozen foods
Core regulations:

ASEAN Food Safety Framework: refer to international standards (Codex), some countries (such as Singapore and Malaysia) require HACCP certification.

Halal certification (Halal): Muslim countries such as Indonesia and Malaysia require cold chain food to meet halal standards.

Temperature requirements: usually refer to international standards (frozen ≤-18℃, refrigerated ≤4℃).

2. Core standards for China’s cold chain food exports
3. Domestic regulatory basis
   “Food Safety Law”: requires food production enterprises to establish a full traceability system.

“Import and Export Food Safety Management Measures” (General Administration of Customs): requires exported food to meet the standards of the importing country.

GB 31605-2020 “Food Cold Chain Logistics Hygiene Specification”: stipulates the temperature control requirements for cold chain transportation and warehousing.

2. International certification system

(1) HACCP (Hazard Analysis and Critical Control Points)

Scope of application: aquatic products, meat, dairy products, frozen foods, etc.

Core requirements:

Identify critical control points (CCPs), such as freezing temperature, processing hygiene, etc.

Establish monitoring, correction and verification procedures.

International recognition: The United States (FDA), the European Union, Japan, etc. all require or recommend HACCP certification.

(2) ISO 22000 (Food Safety Management System)

Integrates HACCP principles and applies to the entire food supply chain.

Widely recognized in the EU and Southeast Asian markets.

(3) BRCGS (British Retail Consortium Standards)/IFS (International Food Standards)

Mainly for food companies exporting to the EU, large supermarkets (such as Carrefour and Metro) require certification.

Covering food safety, quality management and cold chain compliance.

(4) GMP (Good Manufacturing Practice)

Both the US FDA and the EU require food companies to comply with GMP standards.

This involves plant hygiene, equipment cleaning, personnel training, etc.

III. Compliance Challenges and Response Strategies

1. Main Challenges

Standard Differences: Different markets have different temperature and testing requirements (e.g., EU allows for brief heating of frozen foods, while the US requires strict constant temperature).

Testing Barriers: Japan’s Positive List System and EU antibiotic residue standards are stricter than China’s national standards.

High Certification Costs: HACCP, BRC, and other certification fees are high, putting a lot of pressure on small and medium-sized enterprises.

2. Response Suggestions

Study target market regulations in advance: such as the US FDA and EU No 853/2004.

Establish a full-process temperature control system: Use IoT temperature monitoring to ensure compliance during transportation.

Obtain international certifications: Prioritize HACCP, ISO 22000, and other certifications.

Cooperate with professional logistics providers: Choose logistics service providers with international cold chain qualifications (such as DHL Cold Chain and SF Express Cold Chain).

IV. Future Trends
Application of intelligent temperature control technology: Blockchain traceability + real-time temperature monitoring will become the standard for export.

International standards are becoming stricter: Europe and the United States may further raise the microbial and residue limit standards for cold chain foods.

Green cold chain development: Low-carbon refrigeration technology (such as liquid nitrogen freezing) may become a new requirement.

Chinese cold chain food export companies need to continue to pay attention to changes in international regulations and strengthen compliance management in order to maintain competitiveness in the global market.