China Fertilizer Regulations

China Fertilizer Product Compliance Requirements

Competent Authority

Qualification of Applicants

1) Domestic Applicants: Chinese manufacturers

Fertilizer manufacturers in Chinese mainland area, with independent legal entity and business license, including sino-foreign joint venture.

Domestic applicants should firstly apply for production capacity assessment and material preliminary review to the provincial agricultural and rural departments, and then apply for product registration to the National Ministry of Agriculture and Rural Affairs (MOA).

2) Overseas Applicants: Fertilizer manufacturers outside Chinese mainland area such as Hong Kong, Macao and Taiwan, or Fertilizer manufacturers from other foreign countries.

Overseas applicants can also apply for fertilizer registration, but before application the overseas applicant needs to designate a Chinese legal entity as the only representative responsible for the work of fertilizer registration, importing and etc.

Types of Fertilizer Registration

1) Fertilizer Registration

For fertilizer products that need field demonstration test and trial sale after field plot test, the producer shall apply for fertilizer registrations.

The validity period of the fertilizer registration certificate is 5 years. To remain the validity of the registration certificate, a renewal application shall be handled 90 days before the expiration of the validity period.

2) Renewal Registration

If it is necessary to continue to produce and sell the product, the producer shall apply for renewal of registration within 90 days before the expiration of the registration certificate

The renewal registration is also valid for 5 years.

3) Modification Registration

Within the validity period of the registration certificate, if the product’s use scope, name and enterprise name are changed without involving the product quality, the producer shall apply for the modification registration.

4) Fertilizer Filing Record

According to the Notice on Filing Management of Some Fertilizer Products (MOA Office [2020] No. 15) issued by the China MOA, the registrations of 7 types of fertilizers including: water-soluble macronutrient fertilizers, water-soluble fertilizers containing calcium and magnesium, water-soluble fertilizers containing micronutrients, magnesium potassium sulfate for agriculture, magnesium potassium chloride for agriculture, bulk blending fertilizer and compound fertilizer shall be cancelled and the compliance requirements of these 7 types of fertilizers should be changed into filing record management. The filing record is long-term valid.

 Classifications of Fertilizer Products Requiring Registration Compliance

Compliance Processes of Different Fertilizer Registrations

• Fertilizer Registration Process

2）Renewal Registration Process

• Modification Registration Process

2.6. Prohibitive Requirements of Fertilizer Products

For fertilizer products with the following circumstances, the registration application will not be accepted:

• Foreign products with no certificate of use (registration) in origin countries.
• Products that do not meet the national industrial policy.
• Products with disputed intellectual property rights.
• Products that do not meet national or industry standards requirements for safety, health, environmental protection, etc.
• MOA has made the decision not to accept the approval or refuse the approval in less than a year due to the reasons that the applicant conceals the facts or provides false materials in fertilizer registration.
• Before the product registration approval is completed, the same applicant submits the same product registration application.

2.7. Punishment Warnings

According to Administration of Fertilizer Registration issued by the Ministry of Agriculture and Rural Affairs of China, relevant responsible person will get punished if follow business behaviors happen.

2.7.1 In the following cases, the agricultural administrative department will give warnings and fine that is not more than 3 times of illegal income, and the maximum fine will not exceed ¥30,000; if there is no illegal income, the fine shall be ¥10,000 or less.

(1) Producing and selling fertilizer products that do not have registration certificates.

(2) Counterfeiting fertilizer registration certificates or registration certificate numbers.

(3) The active ingredients or contents of the fertilizer products produced or sold are inconsistent with the contents registered on the registration certificate.

2.7.2 In the following cases, the agricultural administrative department will give warnings and fine that is not more than 3 times of illegal income, and the maximum fine will not exceed ¥20,000; if there is no illegal income, the fine shall be ¥10,000 or less.

(1) Transferring the fertilizer registration certificates or registration certificate numbers.

(2) Fertilizer product continues to be produced without the approval of renewal registration after the expiration of the registration certificates.

(3) There is no label on the product package; the label is incomplete; or the label content is modified without authorization.

3. What Fertilizer Compliance Services REACH24H Can Offer?

China Fertilizer Registration Consultation

• Fertilizer Registration
• Renewal Registration
• Modification Registration
• Fertilizer Filing Record
• Field Test Supervision
• Annual Quality Inspection
• Sample Testing
• Label Management
• Fertilizer Regulation Training

EU Fertilizer Registration Consultation

U.S. Fertilizer Registration Consultation

4. Compliance Capability of REACH24H Consulting Group

REACH24H has been dedicated to studying and following Global Fertilizer and Pesticide Regulations since 2014. After 9 years compliance experience, we are specialized in providing agrochemical (i.e. fertilizer and pesticide) regulatory compliance services in China, USA and Europe. By providing the one stop service, REACH24H has helped Top 200 global fertilizer or pesticide enterprises fully fulfil the compliance requirements of China，EU and USA fertilizer and pesticide registrations including product registration type analysis, data gap analysis, compliance analysis strategy report, trail supervision, registration dossier preparation and submission, etc.

Over the years of compliance, REACH24H has also developed very good relationship and close networks with lots of global fertilizer and pesticide government authorities and testing laboratories in China, Europe and the USA etc., all these relationships would help us access the latest news of regulations, better understand regulations, timely know law enforcement actions from competent authorities, speed up application process, and save costs.