China Wine Regulations

National food safety standard systems provide the backbone for supervision of wine products in China. In 1984 the former Department of Light Industry released QB 921-84 Wines and Their Test Methods, the implementation marked the beginning of standardized manufacture of wines in China. From 1994 to 2004, the industry standard “QB/T 1980-1994 Half Base Wine” left a regulatory loophole open allowing manufacture of blended wines with chemical components. The market chaos caused by this oversight didn’t end until 1st Jul 2004 when blended wines were officially banned. Following this China began more reform of wine-related standards and rules, including the drafting of new standards and provisions. In 2013 the NHFPC was created and replaced the former Ministry of Health and National Population and Family Planning Commission. The NHFPC is responsible for setting national food safety standards in accordance with provisions in Food Safety Law.  

Part 1 The growing demands for imported wines

China is one of the world’s most promising emerging wine markets. As a result of the booming Chinese economy recent years have witnessed an explosive expansion in the demand for imported wines.  

In the past domestic brands such as Changyu, the Great Wall and Dynasty have accounted for around 90% of total domestic wine sales. The historically poor market share occupied by imported wines was partly due to Chinese consumers’ unfamiliarity with foreign brands and also associated with the inherent lack of wine drinking culture in China.

Globalization has caused a massive transformation in the Chinese consumer mindset. Chinese consumers are increasingly looking for high quality imported wines. This demand coupled with a change in drinking habits amongst the younger generations has provided fertile ground for growth in the imported wine sector. Wine-drinking has taken root in the more developed east of China where the upwardly mobile middle-class is seeking alternatives to their more traditional upbringings. France remains the dominant exporter with a market share of 35.7% of all imported wines in China as per the data from 2013 while Australia and Chile as new world wine makers are quickly gaining ground.

Recently the Chinese government has launched a new initiative aimed at strictly controlling government expenditure on receptions, vehicles and overseas trips, also known as “the three public consumptions”. Since its implementation the reduction of superfluous spending has been accompanied with declines in sales of a range of products including imported wines. This move has had a significant impact on high-end wine sales as previously governmental purchasing represented a significant proportion of total sales. Considering that growing interests among domestic consumers the future prospects of imported wines especially table wines are extremely bright despite the recent government anti-corruption reforms.

In view of the treaty with the World Trade Organization, import tariffs of agricultural products (wine products contained) in China shall be cut below 5% before 2015 when the extended transitional period of 15 years will come to an end. With costing reduced, imported wines will be more competitive than ever before.

Part 2 China’s regulations and standards for wines

Most regulations overseeing the importation of alcoholic beverages generally apply to that of wines. In addition, there are also some specific regulations and standards made regarding the manufacture, procurement, sales and other aspects of wines.

Before QB/T 1980-1994 Half Base Wine expired on 1 Jul 2004, water-blended fruit wines were permitted for sale in China and could be labeled wine. After the standard was repealed China began a widespread reform campaign targeting relevant standards and regulations bringing about a well supervised regulatory system backed by sound legislation.

Major Wine Regulations Effective in China

Measures for Administration of Alcohol Circulation, 2005 merely serves as a departmental regulation promulgated by the Department of Commerce. The associated legal obligations are rather weak in comparison to the rest of the legal hierarchy governing wines. The revised version of Measures for Administration of Alcohol Circulation, 2012 yet to come into effect includes several amendments but is still inadequate to provide an effective and comprehensive national administrative regulation for alcohol. Several provinces and cities have already had localized alcohol administrative regulations implemented, which have successfully stimulated the smooth development of regional alcohol industry. There is no lack of comparable precedents since overarching regulations for other special foods like dairy, genetically modified foods and salt have been formulated. Article 101 of Food Safety Law has already laid a legislative keystone for construction of a stable alcohol administrative and legislative system. (The Law shall be applied to the safety management of dairy, genetically modified foods, raw pork, alcohol and edible salt, except as otherwise stipulated, Article 101, Food Safety Law)

Since Geographical Indication Product Protection Regulation became effective in 2005, Champaign, Bordeaux, NAPA VALLEY NV and several other terms have gained geographical protection in China. This regulation is quite linked to similar regulations like EU’s Protected Designations of Origin (PDOs), and will help reduce the number of counterfeit products in the Chinese market.

Mandatory National Standards for Wines

Recommended Standards for Wines

Regulatory Updates

Part 3 Competent authority

The General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ)’s main supervisory scope is the import and export inspection of wines.

National Health and Family Planning Commission (NHFPC) holds the obligation of drafting and releasing national standards related to wines.

Part 4 Tips on wine export to China

There are several checkpoints that wine exporters, agents and importers should pay attention to when trading wines in China.

The filing of exporters or agents with AQSIQ

According to Administrative Provisions on Filing of Importers and Exporters of Imported Foods (AQSIQ Order 55 of 2012), overseas exporters or agents shall fulfill record filing obligations with AQSIQ through the filing management system (http://ire.eciq.cn) prior to exportation. The application form for filing should be submitted through the online platform with information such as authentic names of the exporter or agent, country/region, address, contact person, phone number provided.

After submitting the application form, exporters or agents will receive a file number and an inquiry number produced by the filing management system and with these numbers they can check their filing proceeding status and amend filing information.

The filing of importers or domestic agents with CIQs

Consignees (importers or domestic agents) shall apply for filing to the CIQs in local industry and commerce registration centers; the documents required may vary for different ports but in general are required as follows:

• An accurately completed application form for consignee filing
• A copy of industry and commerce business license, organization code certificate, identification paper of the legal representative, registration form for the filing and recording of foreign trade operators, with the original submitted for verification at the same time
• Documents on quality and safety management system of the enterprise
• Documents on organization structure, department functions and job responsibilities concerning food safety
• Documents on planned food category of operation and storage location
• Explanations, including the food category and quantity, reporting on the last two years’ history of food importing, processing and marketing

Similar to exporter filing, consignees need also fill and submit the application form through the filing management system (http://ire.eciq.cn) and obtain a filing number.

After products are imported, importers must keep the import and sales information on record for a minimum of 2 years for future reference. Detailed information includes filing documents of imported record, product supply chain, complaint/recall record, filing documents of sales record.

The filing of labels of wines (AQSIQ Notice No. 59 of 2011)

From 1 June 2011 AQSIQ implemented the prepackaged food labeling management system. For wines imported for the first time, importers shall submit required documents to local CIQs for compliance verification. An IT then automatically generates a filing number for all qualified products. Upon re-importation, products with an existing filing number can forgo extended inspection of Chinese label (subject to permission from CIQs).

Documents required may vary from different ports but in general are as follows:

• Paper copy of Chinese label and attachment of specific information (which should include the name of manufacturer, Chinese name of the brand, physical contrast, etc.)
• Electronic copy of Chinese label (which should be generated via the software “Aided Input Tool for Label Management System” attainable at AQSIQ website after inputting relevant information)
• A copy of original label and translation (which can be skipped provided that the label in Chinese rather than in other languages has been attached at arrival to the port). On condition that ingredients and food additives have not been comprehensively listed on the original label, a complete ingredient list of both English and Chinese shall be submitted separately
• In case that certain contents such as award-winning, certificate-wining, AOC and geographical indication are highlighted in the label, corresponding certificate and translation shall be provided.

USA’s wine export certificate (applicable to US wines only)

As was agreed with the US competent authorities, General Administration of Customs and AQSIQ jointly announced that since 1 Mar 2014 a wine export certificate will be used as a multi-purpose certificate for wine products exported to China. Hence Certificate of Origin, Certificate of Health Sanitation or Certificate of Authenticity/Free Sale will no longer be issued from US authorities for the Chinese wine market. (Notice No. 164, 2013 of AQSIQ and GAC)

Part 5 Requirements of labeling in Chinese

Imported wines in China require back labels in simplified Chinese corresponding to original labels and products attached prior to market circulation. There are two options: use label stickers placed on top of the original labels before the batch of wines is exported to China or conduct the process at port/bonded area. Either way requires label filing with AQSIQ and compliance check after arrival.  

According to GB 15037-2006 Grapes, GB 7718-2011 General Standard for The Labeling of Prepackaged foods, GB 10344-2005 General Standard for The Labeling of Prepackaged Alcoholic Beverage and Article 42 of Food Safety Law, information required on the labels of imported wines include: name, type and vintage of product, ingredients, alcohol content, country of origin, net content, manufacturer, name, address and contact of distributor, storage conditions, filling date and shelf life, food additives, barcode, etc.

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figure1: China wine compliance flow

Information such as country of origin, filling date shall be consistent with documents provided by the exporter or overseas agent. Filling dates require certificates of bottling dates provided by producers.

Food additives must be shown on the label. Sulfur dioxide is the most commonly used food additive in wines. If other food additives are used the labeling of these food additives shall be in line with requirements in GB 2760-2011 Standard for Usage of Food Additives.

If specific information outlining awards and accolades are included certificates and other valid proof shall be submitted for check.

In accordance with GB 7718-2011, the health warning “过度饮酒有害健康” , which means excessive drinking will harm your health, shall be presented on the label.

On condition that the original label is not fully covered by the Chinese one, the foreign language content exposed shall be translated and presented on the Chinese label.

Part 6 Tariffs

High tariffs have been imposed on imported wines in China which in turn will raise the retail prices. In general, the tariffs of bottled wines are as follow:

Import tariff: Tariff rate of wines for most favored nations have been lowered from 43% to 14% since 2005. CIF x 14%

VAT (value added tax) tariff: 17%. (CIF + tariff) x 17%)

Consumption tariff: 10% [(CIF + tariff)/ (1-10%)] x10%)

The sum total rate of tariffs for bottled wines should be 41%. VAT and consumption tariffs also apply to domestic wines.

It is notable that import tariffs can vary between countries. New Zealand has the advantage of Free Trade Agreements (FTA) meaning its import tariff rate for wine has been zero since 2012. Chile is also the beneficiary of FTA, and its import tariff rate is estimated to drop to zero in 2015 and is currently 1.4% (2014).

Import tariff rate of bottled wines for major wine exporting countries in China

Country	Tariff rate as of 2014	FTA	Note
France	14
Australia	14		FTA under negotiation
Chile	1.4	√	FTA initiated since 2006
Italy	14
USA	14
New Zealand	0	√	FTA initiated since 2008
Spain	14
Argentina	14

For bulk wines of more than 2 liters per package the imported tariff rate is 20% (under MFN condition) provided single packaged products of less than 2 liters remains at 14%.

Service

Close ties with Chinese governmental authorities has afforded us accurate and exclusive information. Our experienced expert panel, Food Compliance Service Team (FCS) in REACH24H will provide you one-stop service to remove every barrier in exporting your products to China. Our wine compliance service covers a wide range, including but not limited to general consultancy, coordination and communication with competent authorities, label design, reviews & translation, label filing, exporter & importer filing, product testing arrangement & assistance, trandmark registration, Chinese brand naming and logo design.  Please go to our Consultation Page for more Information.