On 8 September 2026, China's General Administration of Customs (GACC) published Announcement No. 136 of 2026 on fitness inspection of containers used to ship export perishable foods and frozen products. An official policy interpretation followed on 9–10 September. The regime applies to relevant exports from 1 October 2026 and prevails where earlier rules conflict.
Coverage is defined by a dynamic tariff-code list on the GACC import-export food safety portal (jckspj.customs.gov.cn). Codes can change, so mixed containers must be screened HS code by HS code rather than by broad category habit. Covered goods require containers that are clean, hygienic, refrigerated where needed, and sealed-tight (清洁、卫生、制冷、密固) and suited to the cargo.
The operating model shifts to enterprise compliance assurance plus customs review and spot checks. Before loading, the carrier, stuffing unit, or agent applies through the China International Trade Single Window outbound-container fitness module and uploads an Export Container Fitness Conformity Declaration. Applications go to the customs office where the container is stored—not necessarily the export port—which matters for inland stuffing.
Fitness results are valid for 21 days and expire automatically. At export declaration, customs systems validate and write off the result; failed validation triggers rejection (退单). Inspecting too early relative to vessel cut-off forces a re-inspection; presenting cargo without a valid result stops the shipment at paperwork.
Yinglong Insight, summarizing the official text and interpretation, advises food producers and exporters to reverse-plan from vessel cut-off, treat the conformity declaration as a controlled compliance record, re-check the code list on every consignment, and put Single Window filing deadlines into logistics contracts with carriers and stuffing contractors.