Exporting pet food to China

July 1, 2026 - Industry - Tagged: , , - no comments

Proactive regulatory compliance key for European firms

China’s pet food[1] market continues to expand rapidly, driven by rising pet ownership and demand for premium nutrition among urban consumers. For European companies seeking to enter or expand in this market, strict adherence to China’s regulatory framework is essential. Non-compliance can result in shipment rejections, product destruction, financial losses and reputational damage. In this article, David Ettinger and Jenny Xin Li outline the current regulatory landscape and highlight recent updates to underscore the importance of proactive compliance for companies exporting pet food to China.

Pet food in China is classified and regulated primarily as feed rather than human food. The principal governing instrument is the Regulation on the Administration of Feeds and Feed Additives.[2] In 2018, the Ministry of Agriculture and Rural Affairs (MARA) issued Notice No. 20,[3] establishing a dedicated regime through:

  • the Administrative Measures for Pet Food;
  • the Provisions on the Labelling of Pet Food; 
  • the Provisions on the Hygiene of Pet Food; and
  • the Licensing Requirements for Pet Food Manufacturers.

These measures distinguish between formula pet feed (staple foods), pet feed additive premixes and other pet foods (such as treats and snacks), with each having different requirements.

Regulatory oversight for pet food is shared between the MARA, which primarily handles product registration, ingredient approvals and hygiene requirements, and the General Administration of Customs (GACC), which manages facility registration,[4] inspection and quarantine, and border clearance. It should be stressed that imported pet food must originate from countries/regions on the GACC’s approved list. Multiple EU Member States are currently eligible to export pet food to China.

Ingredients used in pet food must be drawn exclusively from the Catalogue of Feed Ingredients[5] and Catalogue of Feed Additives[6] published by the MARA. Use of unlisted substances or additives exceeding permitted limits constitutes a violation. The safety and quality of pet food must also satisfy China’s requirements (e.g., the safety norms for feed).   

Core compliance requirements for pet food

European manufacturers must complete a multi-step process before their first shipment of pet food to China:

  1. GACC overseas manufacturer registration: All production, processing or storage facilities must be registered with the GACC prior to export. Registration confirms that the facility maintains hygiene controls equivalent to Chinese requirements.
  • MARA product registration: Product registration is mandatory for formula pet feeds and additive premixes. The application, which must currently be submitted through a Chinese agent, includes detailed dossiers on formulation, manufacturing processes, safety data and quality specifications. Other pet foods (treats) are generally exempt from MARA product registration but remain subject to the above GACC facility rules.
  • Labelling: All imported pet food requires a compliant Chinese-language label affixed to or printed on the packaging. The mandatory national Feed Label (GB 10648-2013)[7] standard and the Provisions on the Labelling of Pet Feed set the specific labelling requirements, such as product name, ingredient list, guaranteed nutritional analysis, net content, storage, usage directions, expiry dates, manufacturer and importer details, and the relevant registration licence number (where applicable).
  • Inspection and quarantine: Port entry of pet food requires an animal and plant quarantine licence in certain cases (canned wet foods are often exempt). The GACC conducts a document review, sensory inspection and possible laboratory tests for various contaminants, microbes and residues. Non-compliant consignments are returned or destroyed at the importer’s expense.

European exporters benefit from the fact that many EU facilities already operate under high sanitary standards (e.g., hazard analysis and critical control point-based systems), which facilitates GACC approval. However, differences in ingredient lists, nutritional levels and labelling formats frequently require product reformulation or dedicated China-specific variants, which incur additional regulatory burdens.

Upcoming regulatory changes to pet food

Given the increasing demand for pet food, the Chinese Government has been actively crafting new or amending existing regulations and standards to strengthen the management of pet food. In March 2026, the MARA issued the Feed Quality and Safety Supervision Work Plan 2026 (Plan),[8] with pet feed receiving dedicated regulatory attention alongside traditional livestock and poultry feed categories, reflecting the expanding scope of feed safety governance to cover companion animal nutrition products.

Specifically, the Plan mandates conducting quality and safety risk monitoring for pet feed as part of the government’s small variety feed product risk warning responsibilities, establishes the authentication methods for adulterated raw materials used in animal protein feed for pets, and develops evaluation specifications for claimed functions of pet feed. Moreover, under the supervision sampling detection items of the Plan, pet feed is listed as a distinct product category with specific testing requirements, including for crude protein, crude fat, heavy metals such as lead, arsenic and cadmium, and multiple mycotoxins including aflatoxin B, deoxynivalenol, zearalenone, ochratoxin A, fumonisins and T-2/HT-2 toxins. Companies should take note of these new requirements as the enforcement agency is likely to include these parameters for compliance checks during the import process and post-market surveillance. 

In addition, it is worth recalling that in August 2025, the MARA released drafts of two new mandatory national standards pertaining to pet food – the Hygienic Standard for Pet Food[9] and the Pet Food Label Standard,[10] with the former aiming to enhance the hygiene level of pet food. For the first time, it systematically established the mandatory hygiene and safety requirements for pet food in China, with a focus on prescribing the limits for various hazardous substances in pet food, thereby addressing the core issue that pet food hygiene and safety currently lack mandatory standards to rely upon. Once these two standards are finalised and published, they will impose binding hygiene limits and enhanced labelling obligations across the sector. European pet food exporters will need to monitor official announcements to implement some China-specific quality assurance systems addressing these particular risk factors, and align formulations and labels accordingly, as the standards are expected to raise the bar on microbial, heavy-metal and nutritional parameters for future exports.

Conclusion

China’s pet food regulatory landscape is undergoing substantial transformation, characterised by increased standards, intensified enforcement and the systematic integration of pet feed into national feed safety governance. For European companies, success in this market demands not just transactional compliance but active engagement with regulators. For instance, companies could get involved in the standard-setting process to be proactive and create forward-looking compliance obligations. The pending mandatory national standards discussed in this article will likely reset industry benchmarks, creating both compliance burdens and competitive opportunities. Manufacturers that invest now in understanding and anticipating these regulatory developments will be best positioned to navigate the evolving terrain and capture opportunities in one of the world’s most dynamic pet food markets.

David J. Ettinger is a partner at Keller and Heckman LLP.

Jenny Xin Li is a counsel working at Keller and Heckman LLP’s Shanghai Office.

Keller and Heckman LLP is an international law firm that provides regulatory compliance services to companies and industry associations around the world, e.g., foods, feeds (including pet foods), consumer products, chemicals etc.

[1] ‘Pet food’ and ‘pet feed’ in China share the same definition: a product that has been industrially processed and prepared, and directly offered for consumption to pets (e.g., cats and dogs).

[2] Regulations on the Administration of Feed and Additives, Ministry of Ecology and Environment, 3rd November 2011, viewed 19th May 2026, <https://www.mee.gov.cn/zcwj/gwywj/202001/t20200114_759349.shtml>

[3] Announcement No. 20 of the Ministry of Agriculture and Rural Affairs of the People’s Republic of China, Ministry of Agriculture and Rural Affairs, 20th May 2018, viewed 19th May 2026, <https://www.moa.gov.cn/nybgb/2018/201805/201806/t20180620_6152699.htm>

[4] Measures for the Supervision and Administration of Inspection and Quarantine of Import and Export Feed and Feed Additives, General Administration of Customs of China, viewed 25th May, 2026, <http://gdfs.customs.gov.cn/customs/302249/zfxxgk/hggzk/4081684/index.html>

[5] Catalogue of Feed Ingredients, Ministry of Agriculture and Rural Affairs, 30th June 2025, viewed 19th May 2026, <https://www.moa.gov.cn/ztzl/sqxzjcgs/xzjcbz/202506/t20250630_6475262.htm>

[6] Catalogue of Feed Additives, Ministry of Agriculture and Rural Affairs, January 2026, viewed 19th May 2026, <https://www.nahs.org.cn/xxcm/slpj/202109/P020260119324203999078.pdf>

[7] Standard number: GB 10648-2013, National public service platform for standards information, 10th October 20213, viewed 19th May 2026, <https://openstd.samr.gov.cn/bzgk/gb/newGbInfo?hcno=F08C4A6B7F30AE0E94AC9CEE37F8391C>

[8] Feed Quality and Safety Supervision Work Plan 2026, Ministry of Agriculture and Rural Affairs, 5th March 2026, viewed 19th May 2026,  <https://www.chinafeed.org.cn/xwdt_10092/hyxw/202603/P020260321767355302838.pdf>

[9] Hygienic Standard for Pet Food (Draft for Comments), National public service platform for standards information, 11th August 2025, viewed 19th May 2026, <https://std.samr.gov.cn/gb/search/gbqSuggestionDetail?id=E74132B2C2E8AF2FE0FC3A8C31DB8E20>

[10] Pet Food Label Standard (Draft for Comments), National public service platform for standards information, 11th August 2025, viewed 19th May 2026, <https://std.samr.gov.cn/gb/search/gbqSuggestionDetail?id=45F533FD9BF81716FC08848908D46FDC>

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