GACC Announcement No. 136: Changes to the Fitness-for-Carriage Inspection Model for Containers of Frozen Export Goods!

On September 8, the General Administration of Customs (GACC) issued Announcement No. 136 of 2026, setting out rules for the fitness-for-carriage inspection of containers used to ship export goods that are perishable or subject to spoilage and frozen goods, effective October 1, 2026. The announcement specifies the range of goods codes subject to container fitness-for-carriage inspection and provides for dynamic management; the list is somewhat shorter than the previous one. The inspection model has been optimized and adjusted from "enterprise pre-inspection + customs spot checks" to "enterprise compliance assurance + customs review and spot checks." The specific codes are subject to the list published on the GACC portal website.

The statutory requirements for fitness-for-carriage inspection are four: cleanliness, hygiene, refrigeration and tightness. For frozen goods, "refrigeration" directly corresponds to the cooling performance of the reefer container, and "tightness" relates to how well the container body is sealed; if any one of these fails, the risk of cargo damage on long routes falls on the enterprise itself. The annex to the announcement lists 10 inspection items and 7 pass/fail criteria, with additional specific requirements for reefer containers and tank containers.

Fitness-for-carriage inspection is not a newly created threshold. The Law on Import and Export Commodity Inspection and its implementing regulations already provide that, for containers used to ship export goods that are perishable or subject to spoilage and frozen goods, the carrier, the stuffing unit or its agent shall apply for fitness-for-carriage inspection covering cleanliness, hygiene, refrigeration and tightness before shipment; shipment is not permitted without inspection or if inspection fails. The core of Announcement No. 136 is to clarify the range of goods codes and to optimize and adjust the inspection model.

In terms of procedure, the carrier, the stuffing unit or its agent submits an inspection application before shipment through the outbound container fitness-for-carriage inspection module of the "China International Trade Single Window" to the customs office at the place where the container is stored, uploading the "Export Container Fitness-for-Carriage Compliance Statement" as an attachment; customs reviews the statement and conducts risk-based spot checks on the container, and containers that pass are permitted for shipment. Inspection results are valid for 21 days and automatically lapse after that period.

System verification has also been added at the export stage. When an enterprise declares the relevant goods for export, the customs IT system automatically verifies the container fitness-for-carriage inspection results, and export declarations that fail verification are returned in accordance with the law. This means that if goods within the list range have no fitness-for-carriage inspection record, or if the inspection results are beyond the 21-day validity period, the declaration will be returned directly by the system at customs declaration.

For frozen goods exporters, this announcement brings three direct changes. First, the subject responsibility is stated more concretely: the announcement requires producers and operators of export goods that are perishable or subject to spoilage and frozen goods to strictly implement their food safety subject responsibility, to self-inspect containers, and to select containers that are clean, hygienic, properly refrigerated and tight for shipment; the inspection requirements are published in the annex to the announcement. Second, responsibility moves earlier: shipment is permitted only after spot checks pass, so enterprises need to complete the application before the booking and stuffing stages, and the statement content must truthfully reflect the container condition. Third, time management becomes a new task: fitness-for-carriage inspection results are valid for only 21 days, so stuffing, customs declaration and sailing must all be scheduled around this cycle; if the validity period is exceeded, re-inspection is required.

The announcement also clarifies that, where previous provisions on fitness-for-carriage inspection of containers used to ship export goods that are perishable or subject to spoilage and frozen goods are inconsistent with Announcement No. 136, the new announcement prevails. From publication on September 8 to entry into force on October 1, the transition window left to enterprises is only 23 days; during this period, enterprises need to check whether their products remain within the fitness-for-carriage inspection list and become familiar with the Single Window declaration process.