Notice No. 146/2026 of the General Administration of Customs of China (GACC) stipulates that grain imported into China must be processed and used at "designated processing enterprises". Document issued on October 13, 2026 and effective from November 15, 2026. The direct obligation belongs to the buyer and the processing enterprise in China, but Vietnamese exporters need to proactively ask the buyer so that the shipment is not delayed.
What does Notice 146/2026 GACC regulate?
The original text name is 海关总署公告2026年第146号(关于优化进境粮食企业监管措施及有关事宜的公告), roughly translated: Thong Paper No. 146 of 2026 "on optimizing enterprise management measures for imported grain and related issues". According to the original text posted on GACC's site, the main points include:
- Imported grain must be processed and used at designated processing enterprises (指定企业) with conditions for disease prevention and handling.
- Enterprises in China that want to process imported grain self-assess and submit a "declaration of conformity" through the National Single Window or Customs Online Service Portal; After customs approval, it can operate.
- When applying for an entry animal and plant quarantine permit (检疫许可证), the goods owner must identify the designated enterprise that will receive the goods and submit supporting documents, or use the "Contact form for preliminary examination of imported grain" (进境粮食初审联系单).
- If an enterprise indicates a violation (failure to prevent spillage, failure to handle eradication, failure to treat waste products, refusal to supervise), the customs office will not issue a quarantine permit for the next shipment to that enterprise until it is corrected.
Scope of "cereals" in Notice 146
According to the text, "cereals" (粮食) include seeds of cereal crops, beans, oil crops, and tubers and roots of tuber crops (薯类) used for processing, not as seeds. So the range is quite wide, not just wheat or corn.
| Group by text | Common examples | Notes for Vietnamese goods |
|---|---|---|
| Cereal seeds | Corn, rice, wheat | Need to compare the purpose of use stated on the quarantine permit |
| Bean | Soybeans, green beans | Ask the buyer about the designated business |
| Oil tree | Peanuts, sesame | Ask the buyer about the designated business |
| Tubers and roots are used for processing | Dried cassava slices | There is no official confirmation guide specifically for each Vietnamese product |
Whether each specific Vietnamese product (cassava chips, rice, corn...) is applicable or not, there is currently no separate official guidance. Businesses should confirm with buyers and competent authorities before signing a contract.
Who is affected and how?
Chinese side
Shippers, import agents and processing enterprises in China are the direct subjects. The buyer must have (or work with) a designated processing enterprise to obtain a quarantine permit for the shipment.
Vietnamese exporter side
The impact is indirect: if the buyer has not prepared the designated business, the quarantine permit may be slow, leading to slow loading and customs clearance of the shipment. If the designated enterprise is handled for violations, subsequent batches transferred to that enterprise will also be affected.
What should exporters do before November 15, 2026?
- With contracts for cereals, beans, oilseeds or cassava chips delivered after November 15, 2026: ask if the buyer has a designated processing enterprise, and the quarantine license states which enterprise.
- Consider clearly stating in the contract the buyer's responsibilities regarding quarantine permits and the receiving business.
- Compare the information on the quarantine permit with the plant quarantine certificate and set of documents before loading.
- Continue to meet current requirements such as business registration under Order 280 and Notice 219/2025 if the item is in the category.
Frequently asked questions
From what date does Notice 146/2026 take effect?
Document issued on October 13, 2026, effective from November 15, 2026.
Do Vietnamese exporters have to register as designated enterprises?
Are not. The designated enterprise is a processing enterprise in China. The obligation to prepare belongs to the buyer and the Chinese processing enterprise.
Is Vietnamese dried cassava chips eligible?
The document mentions tubers and roots used for processing, but there are no official instructions specifically for Vietnamese cassava chips. You should ask the buyer and the competent authority.
Does this Notice replace Order 280 or Notice 219?
Are not. Notice 146 supplements the management of processing enterprises in China; Current foreign business registration requirements still apply.
Conclude
Notice 146/2026 does not impose additional procedures for Vietnamese exporters, but makes the buyer's quarantine permit dependent on the designated processing enterprise. Communicating early with buyers and reviewing contracts is a simple way to avoid product delays after November 15, 2026.
Reference source
General Administration of Customs of China (GACC), Notice No. 146/2026 on optimizing enterprise management measures for imported grain, issued October 13, 2026, effective November 15, 2026: PDF version on customs.gov.cn. Hong Kong Department of Industry and Trade, trade circular reposting Notice 146: https://www.tid.gov.hk/en/tradecircular/files/2026/ci9072026a.pdf.
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