Shanghai Full Process of Customized Food Import Agency: Key Points of Dual Customs and Inspection & Quarantine Review

Customized Food Import: Compliance Threshold and Practical Pitfall Avoidance Guide at Shanghai Ports

As a foreign trade agency with 20 years of in-depth operation at Shanghai ports,we have seen far too many customized food enterprises stuck in the customs clearance stage due to neglected details: one European jam importer was returned for rectification at the pre-inspection stage because the label did not indicate "sodium benzoate"; one Southeast Asian snack brand had the whole batch of goods detained at the port for 3 days because it failed to complete GACC overseas manufacturing enterprise registration in advance.The very nature of "customization" of customized food amplifies compliance risks — formulas,labels and quarantine requirements can all become clearance bottlenecks.The following part breaks down core operational points for customized food import at Shanghai ports from access licensing to port inspection.

Step 1: Customs Valuation and Declaration Specification — Price Logic from EXW to CIF

Customs valuation is the first checkpoint for imported food.2026 General Administration of Customs Decree No.12 requires that the declared price shall include "transport and related fees,and insurance premiums incurred before the goods are unloaded at the designated entry point within the Chinese territory".Take one customer’s customized chocolate imported from Germany as an example: the quotation was EXW Hamburg,but the actual transportation was handled by our agency.During customs verification,it was found that "land transport fees from Hamburg to Shanghai Port + insurance premiums" were not included,leading to abnormal valuation result.

Key operations: 1.Clear transaction terms: For EXW/FOB terms,domestic segment related fees shall be supplemented; For CIF/CIP terms,verify that the insurance premium calculation complies with the Customs Valuation Agreement; 2.Price adjustment items: Additives,packaging fees,design fees and other items calculated separately shall be included in the dutiable value; 3.Special agreements: Terms such as "exclusive distribution rebate" shall be clearly stated on the invoice to avoid customs identifying it as implicit price reduction.

New Trends of Valuation in 2026

Customs adopts a valuation model mainly based on "cost back calculation method" for "non-standard formula food" (such as functional customized food),so relevant supporting documents including raw material purchase vouchers,processing cost details and reasonable profit margin calculation sheet shall be prepared in advance.

Step 2: CIQ Pre-inspection and Label Compliance — 12 Mandatory Indicators from Ingredient List to Chinese Label

The inspection and quarantine department exercises particularly strict review over customized food labels.One customer’s imported organic jam was required to make rectification before entry because the label missed "allergen warning" (as it contains raspberry).The Chinese label shall meet the following requirements at the same time: 1.Mandatory labeling items (product name,ingredient list,net content,production date,shelf life,country of origin,importer,distributor); 2.Special labeling items (for example,the specific name of food additives shall be clearly marked,and GB 2760-2024 adds new color value restrictions for colorants such as sunset yellow).

Practical pre-inspection checklist:

• The "food additives" in the ingredient list shall correspond to GB 2760-2024 one by one,and vague expressions such as "preservative" are prohibited;
• The nutrition information table shall comply with the mandatory standard GB 28050-2011,and "0g" shall be marked even if no sugar is added;
• The importer information shall be consistent with that on the customs declaration form,with valid Chinese contact person name and phone number provided;
• Vector files of graphic labels shall be submitted simultaneously,to avoid customs questioning the authenticity due to low resolution.

"Three-round Review and Three-round Rectification" Principle for Label Filing

We suggest three rounds of review: the first round is completed by the legal team to verify regulatory provisions,the second round is completed by CIQ specialists to simulate pre-inspection,and the third round is submitted to the GACC filing system for verification.In one Southeast Asian coconut milk import case,we adjusted the description from "natural coconut milk" to "100% natural coconut milk (no added preservatives)" through three modifications,raising the label approval rate from 60% to 100%.

Step 3: Dual Verification of Animal and Plant Quarantine and Import License

If customized food contains animal or plant derived ingredients,dual quarantine procedures are required: 1.Quarantine certificate (for example,import of meat requires "Entry Animal and Plant Quarantine License",and plant-derived food requires "Phytosanitary Certificate"); 2.Enterprise qualification (the importer shall complete "filing of imported food consignee" and be publicly listed on the official website of General Administration of Customs).Note that the newly launched "cold chain food traceability system" in 2026 requires uploading logistics temperature control data 3 working days in advance.

Typical risk point: One batch of Australian dairy products was directly rejected for release during customs clearance because the GACC overseas manufacturing enterprise registration was not completed before shipment (as required by Decree No.248).Correct operation: Check in advance whether the target country is included in the "List of Overseas Manufacturers of Imported Food" published by GACC,and sign the import contract only after confirmation.

2026 Customized Food Import Risk List: 5 Types of Compliance Red Lines You Must Avoid

• Hidden minefield of excessive ingredient content: One batch of customized biscuits was judged as "non-compliant with national food safety standards" by the inspection and quarantine department,as it used sodium dehydroacetate which is restricted under GB 2760-2024;
• Label filing lag risk: One importer submitted the label filing application only after goods arrived at the port,which led to port detention fees;
• Validity issue of quarantine certificate: One customer was returned for rectification by customs with the reason of "certificate expired" as it used a health certificate issued 3 months earlier;
• Discrepancy between declared price and supporting documents: In one case,the importer confused FOB price and EXW cost price,leading the valuation department to determine "untruthful declaration";
• Missing filling of RCEP Certificate of Origin: One ASEAN nut importer missed filling in the country of origin field,thus missing the tariff reduction opportunity.

Zhongshitonggtong Practical Case: Full Clearance Record of One Batch of European Organic Jam Import

Context: One European jam brand imported customized jam (compound formula containing raspberry and blueberry),targeting the Shanghai market in China,with the requirement of completing full-process customs clearance within 30 days.Tasks: Resolve three core issues including label filing,quarantine certificate compliance and valuation dispute.Actions:

• Complete GACC overseas enterprise registration verification 72 hours in advance;
• Find the vague expression "natural pigment" during pre-inspection,and revise it to "edible natural pigment (source: blueberry extract)";
• Apply for the Entry Animal and Plant Quarantine License for the raspberry containing ingredient,and supplement the quarantine certificate of the planting base;
• Submit raw material purchase invoice,processing process description and profit margin calculation sheet during the valuation stage,to convince customs to recognize the declared price.

Result

: The whole clearance process took 28 days,2 days shorter than the customer’s expectation; label filing was approved at the first submission without rectification; finally,5% tariff reduction was realized with valid RCEP Certificate of Origin,saving RMB 120,000 of cost.

Core Advantages of Zhongshitonggtong Customized Food Import Service

As a local Shanghai agency,our differentiated strengths are reflected in three aspects: 1.Port coordination capability: We support cross-port declaration and port release at Shanghai Pudong Airport,Waigaoqiao Port Area and Yangshan Port; 2.Document pre-inspection mechanism: Complete four rounds of verification (regulatory compliance,logic consistency,validity check,correlation check) within 24 hours after receiving customer documents; 3.Global compliance network: We have built mutual trust partnerships with agents in more than 30 countries across EU,ASEAN and North America,and can lock in holiday operation windows in advance (e.g.arrange stocking in advance during the Thanksgiving holiday in the US).

Last reminder: The compliance of customized food shall always be confirmed before the customization is finalized.Any formula adjustment,label design and packaging change shall complete at least two rounds of compliance verification before import.If you are facing similar issues,you can contact Zhongshitonggtong for free pre-inspection service to avoid unnecessary losses caused by minor negligence.