- General trade: the NZ factory needs an MPI recommendation and a GACC registration number
- Declarations must carry that number (licence code 519) and the use "food"
- Selling as a health food: imported fish oil must go through full SAMR registration
- Cross-border e-commerce: no registration or filing, but no function claims
- Traders and brand owners are not the registered entity
- What do you need to export New Zealand fish oil to China?
- After Order 280, does the fish-oil factory need GACC registration?
- Can imported fish oil be sold as a "blue hat" health food?
- Without a blue hat, what other legal routes are there?
- Which customs documents and label details are required?
- Can a trader borrow a factory's China registration number?
1. What do you need to export New Zealand fish oil to China?
It depends on the route. General trade means three layers: the factory holds a GACC registration in China, the Chinese consignee is registered as an importer, and every shipment carries an official certificate and passes port inspection. Marketing it as a health food adds SAMR registration. Cross-border e-commerce retail sits outside all of these.
"What paperwork does fish oil need?" is really three questions, handled by three different authorities:
- Factory level (GACC, China Customs): the New Zealand plant must hold a China registration number.
- Company level (Customs): the Chinese consignee must be registered; each shipment needs an official New Zealand health certificate.
- Product level (SAMR): only if you want to sell it as a health food with function claims does the product itself need approval.
2. After Order 280, does the fish-oil factory need GACC registration?
Yes. Any food imported as goods for human consumption or food processing must carry the overseas manufacturer's China registration number on the declaration; without it, Customs rejects the entry. Health foods, edible oils and fats and aquatic products are all on the 17-category list requiring an official recommendation, so the New Zealand plant must be recommended by MPI.
GACC Decree No. 280 on the registration of overseas manufacturers of imported food was published on 14 October 2025 and took effect on 1 June 2026, repealing Decree 248. Three of its 17 recommendation categories touch fish oil — health foods, edible oils and fats, and aquatic products — so whichever way your product is classified, the factory cannot skip the official recommendation.
In New Zealand the competent authority is the Ministry for Primary Industries (MPI). The usual path is self-assessment, third-party verification, an application for MPI recommendation, and submission through GACC's CIFER system. Under the implementing rules, only products manufactured while the registration is valid may be declared — the production date counts, not the shipping date. Registered plants are listed publicly in GACC's registration system.
3. Can imported fish oil be sold as a "blue hat" health food?
Yes, but it is the hardest route. Article 76 of China's Food Safety Law requires first-time imported health foods to be registered with SAMR; only vitamin and mineral supplements may be filed instead. Fish oil is on the health-food raw material catalogue, but catalogue-based filing currently applies to domestic products only, so imported fish-oil health foods still need registration.
Registration requires a development report, formula, manufacturing process, safety and function evaluations, labels and instructions, plus samples — and the product must already be lawfully on sale in the exporting country. The industry measures review time in years, so budget and timeline should be planned as a long-term project.
4. Without a blue hat, what other legal routes are there?
Three: cross-border e-commerce retail, general trade as an ordinary food, and exporting fish-oil raw material to a licensed Chinese health-food manufacturer that files the finished product domestically. All three are legal, but what you must register and what you may claim differ sharply.
| Route | Factory registered in China | Product registration / filing | Health-function claims |
|---|---|---|---|
| ① General trade · health food | Required | SAMR registration | Allowed (as approved) |
| ② General trade · ordinary food | Required | Not required | Not allowed |
| ③ Cross-border e-commerce retail | Not currently required | Not required | Not allowed |
| ④ Raw material + domestic filing | Required (ingredient plant) | Chinese maker files provincially | Allowed (as filed) |
Route ③ rests on MOFCOM notice Shang Cai Fa [2018] No. 486: cross-border e-commerce retail imports are supervised as personal goods and exempt from first-import licences, registration and filing. The trade-off: sales to individuals only, within personal limits, the product must be on the cross-border positive list (check each HS code), and function claims are still off-limits.
Route ② means the product must meet the relevant Chinese national food-safety standard and its label must not imply health functions. Route ④ imports fish-oil raw material, which is still regulated as food of animal origin, so the New Zealand ingredient plant also needs a China registration number.
5. Which customs documents and label details are required?
Each general-trade shipment needs at least an official New Zealand inspection and quarantine certificate, contract, invoice, packing list and bill of lading, with the factory's China registration number in the "product qualification" field (licence code 519) and "food" as the stated use. Customs inspects at the port, samples where needed, and issues an entry inspection certificate before sale.
The consignee must first register through China's Single Window or the Internet + Customs portal. In a published reply to an importer, China Customs confirmed that fish oil is treated as food of animal origin, and inner and outer packaging must be labelled in Chinese and English (or Chinese plus the exporting country's language) with:
- trade name and scientific name, specification, production date, batch number, shelf life and storage conditions
- the China registration number
- production method (marine catch, freshwater catch or farmed) and production area
- name, registration number and address of every plant involved, including vessels and stand-alone cold stores
- destination marked as "People's Republic of China"
6. Can a trader borrow a factory's China registration number?
Not as its own qualification. The registered entity is the plant that actually produces, processes or stores the food, and each number is tied to one plant and one country of origin. Traders, brand owners and agents are not registered entities; the declaration must show the number of the plant that made that shipment, and anything else is a false declaration.
So when you choose a New Zealand OEM partner for fish oil, the first question is not price but: does this plant hold a China registration number, for which category, and is it still valid?
To be clear about ourselves: Forever Gain HK Holding is a trading and brand-owning company and does not hold a GACC registration number. What we hold is New Zealand trade mark 恩物® Thesaurus (No. 1316638), whose Class 5 covers fish liver oil and nutritional supplements. Our job is to find the right plant, choose the right route, and connect the trade marks, documents and export steps.
Quick self-check: how many of these can you answer?
| Question | Can you answer it now? |
|---|---|
| Is your fish oil going general trade or cross-border e-commerce? | No → choose the route first |
| Will the product make health-function claims? | No → this decides whether you need registration |
| What is the NZ plant's China registration number, and which category? | No → the plant may not be able to ship |
| Is your Chinese consignee registered as an importer? | Yes → you can plan the first shipment |
| Does the Chinese label show the scientific name, production method and registration number? | Yes → half the port risk is gone |
| Is your brand registered as a trade mark in both China and New Zealand? | Yes → no squatting when you list |
Making fish oil in New Zealand under your own brand? Talk to us
We provide trade mark registration assistance in both China and New Zealand, and a one-stop programme from formulation and production through China registration liaison to import. You remain the trade mark applicant; we assist and coordinate. Our own 恩物® Thesaurus is registered in New Zealand (No. 1316638, Classes 5 and 29).
To be clear: we are not an agency designated by GACC, MPI or SAMR, and we cannot guarantee any registration or approval; timing and outcomes rest with the authorities. Minimum orders and sampling lead times are assessed product by product.
The WeChat button opens WeChat directly on your phone; on a computer, WeChat needs to be installed. When you get in touch, tell us your intended route, product format and expected annual volume.
Fish oil and fish liver oil are New Zealand marine ingredients on the "made in New Zealand, consumed in China" path. NZGOCH.COM, driven by Forever Gain HK Holding, is built for exactly that: New Zealand plant sourcing, brand and trade mark, export documents — one window.
NZGOCH.COM · New Zealand marine ingredient OEM →Sources: GACC Decree No. 280 and its implementing lists; Article 76 of the Food Safety Law of the PRC; SAMR raw material catalogue for coenzyme Q10, fish oil and three other ingredients; MOFCOM Shang Cai Fa [2018] No. 486; Gongbei Customs reply on importing fish oil (People's Daily Overseas Edition, 11 April 2026); MPI guidance on China Registration of Food Establishments. Always check the latest official requirements.
Frequently asked questions
What do I need to export New Zealand fish oil to China?
It depends on the route. General-trade imports need three layers: the New Zealand factory must hold a GACC registration number in China, recommended by MPI; the Chinese consignee must be registered as a food importer; and every shipment needs an official New Zealand health certificate and passes port inspection. Selling it as a health food also requires registration with China's State Administration for Market Regulation (SAMR). Cross-border e-commerce retail imports are supervised as personal goods and are exempt from these registration and filing requirements.
Does a supplement factory need GACC registration after Order 280?
Yes. GACC Decree No. 280 took effect on 1 June 2026. Health foods, edible oils and fats and aquatic products are all on the 17-category list that requires official recommendation. A New Zealand factory must be audited and recommended by MPI, then registered through the CIFER system; the registration number must appear on every general-trade customs declaration or the declaration is rejected.
Can imported fish oil be filed as a health food instead of registered?
Not at present. Fish oil has been on China's health-food raw material catalogue since March 2021, but filing on that basis applies only to domestically made products. For first-time imports, only vitamin and mineral supplements can be filed; imported fish-oil health foods still need full SAMR registration.
Do I need a blue hat to sell New Zealand fish oil via cross-border e-commerce?
No. Under MOFCOM notice Shang Cai Fa [2018] No. 486, cross-border e-commerce retail imports are treated as personal goods and are exempt from first-import licences, registration and filing; factory registration in China is not currently required either. But a product without Chinese registration or filing must not make health-function claims, and it must be on the cross-border e-commerce positive list.
Can a trading company declare goods under a factory's China registration number?
The declaration must show the registration number of the factory that actually produced that shipment, which is normal. But the trading company is not the registered entity, cannot present the number as its own qualification, and cannot use factory A's number for goods made by factory B. Each number is tied to one factory and one country of origin; false declarations are penalised.
Can you help with trade mark registration in China and New Zealand?
Yes, we assist. For New Zealand fish-oil OEM clients we provide trade mark registration assistance in both China and New Zealand, plus a one-stop programme from formulation and production through China registration liaison to import. The client is the trade mark applicant; acceptance is decided by the trade mark office in each country.