By Chen Bing and Yang Yue King and Wood Mallesons Shanghai ,China
On September 30, 2016 the China Food and Drug Administration (“CFDA”) released the Circular on the Transition Period for Formula Registration of Infant Formula Milk Power (the “Circular”) This was just one day before the effective date of the Administration Measure for the Registration of Formulas of Infant Formula Milk Powder (“Registration Measure”)according to which formulas of infant formula milk products must be registered before manufacturing or sale in China.
The Circular suspends the formula registration requirements for infant formula milk powder until January 1, 2018, and provides a guideline on the handling of products manufactured or imported before that date.
The Circular appears to be straightforward, however infant formula marketers whether by the traditional business model or through cross-border ecommerce, should be aware of the underlying impacts of this Circular and take preparatory measures during the transitional period.
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