Separating the Myths from the Facts
One of the most persistent misconceptions is that China has a comprehensive ban on milk powder. This stems largely from a history of food safety concerns, particularly the 2008 melamine crisis, which caused immense public alarm and led to sweeping overhauls of the country's food safety legislation. Today, rather than a single ban, China operates a complex and strict regulatory framework that governs the production, sale, and importation of all dairy products, including milk powder.
The Ban on Reconstituted Milk in Sterilized Milk
Effective as of September 2025, and phased in via standards implemented throughout 2025, China has officially banned the use of reconstituted milk in the production of sterilized drinking milk. This major regulatory update means that sterilized milk, including both Ultra-High Temperature (UHT) and pasteurized variants, must be made exclusively from 100% fresh raw milk.
What is Reconstituted Milk?
Reconstituted milk is produced by adding water to milk powder or condensed milk. This process has been a cost-effective method for many producers but is now prohibited in sterilized milk to boost product quality and consumer confidence. The new rules are a direct response to rising consumer preference for 'natural' and 'fresh' dairy products, along with a sufficient domestic raw milk supply.
Stricter Rules for Infant Formula
Infant formula is one of the most tightly controlled products in China, and it is not banned but subject to rigorous market access requirements.
Key requirements include:
- Recipe Registration: Since January 2018, all infant formula products, whether domestically produced or imported, must have their recipes registered with China's State Administration for Market Regulation (SAMR). This certificate number must be clearly displayed on the packaging.
- Overseas Manufacturer Registration: Foreign manufacturers must be registered with the General Administration of Customs of China (GACC).
- On-site Audits: The registration process often includes on-site facility audits to ensure compliance with Chinese standards.
- Traceability: The regulations require robust traceability systems.
Updated National Food Safety Standards for Milk Powder
Beyond specific bans, China continually updates its broader food safety standards. In February 2025, the revised standard GB 19644-2024 for milk powder and modified milk powder took effect. This standard expands the scope to include products made from a wider range of dairy sources, such as yak and camel milk, and introduces new technical and labeling requirements.
Regulation Comparison: Pre-2025 vs. Post-2025
| Feature | Pre-2025 Regulations | Post-2025 Regulations | Impact on Market |
|---|---|---|---|
| Reconstituted Milk in Sterilized Milk | Permitted as a cost-effective option for many brands. | Strictly prohibited; only 100% fresh raw milk allowed. | Higher quality, increased production costs, potential price hikes for consumers. |
| General Milk Powder (GB 19644) | Previous standard GB 19644-2010 focused mainly on bovine milk products. | Updated standard GB 19644-2024 expands scope to include yak, camel, etc., and has new labeling rules. | Broader product category covered, improved clarity and safety for specialty milks. |
| Infant Formula | Recipe registration required since 2018; overseas manufacturer registration ongoing. | Continues rigorous registration and audit process; specific amendments made. | Sustained consumer trust for imported infant formula due to strict checks. |
| Cross-border E-commerce (CBEC) | Evolved with various positive and negative lists; subject to filing requirements. | Infant formula requires registration for sale via CBEC; some adult milk powders may be restricted from CBEC. | Limits grey market imports, favors companies that complete formal registration. |
Importing Milk Powder for Personal Use
Despite the strict commercial regulations, travelers can still bring a reasonable quantity of milk powder into China for personal use. China Customs permits limited, duty-free amounts for gifts or personal consumption. While the definition of "reasonable quantity" can vary based on factors like travel duration, typical allowances exist. However, it's always best to declare any significant quantity and be prepared to pay taxes on amounts exceeding personal limits.
Conclusion: Navigating China's Dairy Market
The idea that all milk powder is banned in China is a sweeping oversimplification. The reality is a highly regulated and sophisticated system designed to address historical safety failures and improve domestic product quality. While the recent ban on reconstituted milk in sterilized milk is a significant restriction, milk powder remains a key ingredient in many other dairy categories like yogurt and formulated milk. For importers and consumers alike, understanding these nuanced rules is crucial for navigating China's evolving dairy landscape. From stringent infant formula registration to limits on personal importation, China's market is governed by precision, not a universal prohibition.
ChemLinked provides excellent, up-to-date information on China's food and chemical regulations.
