China Infant Formula:Formula Registration Rule Is Announced,But Some Questions Remained Unsolved

　　What's new: CFDA announced the final version of the Formula RegistrationRule, which will take effect on October 1, 2016. CFDA will further announce thedetailed rules for implementation (e.g., filling documents, on-site examination,etc.).

　　What comes as unexpected: While the major article is similar to the onefiled to the WTO in January 2016, the followings are out of our expectation:

　　1) Proper Chinese labeling is not required by the Formula Registration Rule, asthe related clause has been removed. We foresee two possible scenarios:

　　Products originated from foreign markets (without Chinese labeling)sold via cross-border eCommerce (CBE) could continue to be sold aslong as they are approved under the Formula Registration Rule. TheMinistry of Finance has provided a grace period for CBE infant formula- the registration rule will not apply on CBE until January 1, 2018.

　　There could be another government announcement that requires CBEproducts to be compliant with AQSIQ No. 2013-133, which articulatesimported infant formula must include printed proper Chinese labeling.