Beyond the Checklist: Why Identity Preservation is the Key to China's New GACC Decree 280

For years, exporting grain to China has felt like a game of “follow the leader.” You registered your facility under Decree 248, checked the boxes for the 18 high-risk categories, and hoped the rules didn’t change mid-voyage.

But the landscape is shifting. On June 1, 2026, China will officially retire Decree 248 and implement Decree 280—a new regulatory framework that moves away from static checklists and toward a risk-based, dynamic management system.

For the American durum wheat industry, this isn’t just another administrative hurdle; it’s a fundamental change in how your supply chain must be structured. Here is what you need to know about the transition and why the "Identity Preserved" (IP) model is no longer a luxury—it’s a requirement for market access.

The Move to Dynamic Risk Management

Under the old rules, products were either "high risk" (requiring official USDA recommendation) or "low risk" (self-registration). Decree 280 replaces this with a dynamic catalog.

GACC will now adjust the registration requirements for specific products based on real-time data, country-of-origin safety assessments, and the historical compliance of the manufacturer. This means a product that is "easy" to export today could be moved to a "high-supervision" list tomorrow if a safety concern arises.

Why "Identity Preserved" is the New Gold Standard

The core of Decree 280 is traceability. China is prioritizing "List-Based Registration" for countries with recognized food safety cooperation. To maintain your spot on that list, every node in your supply chain—from the farm gate to the export terminal—must be transparent.

This is where the Identity Preserved (IP) model excels. While bulk commodity exports often mix grain from hundreds of unknown sources, the IP model (which Wigglesworth utilizes) tracks specific batches of grain back to the individual grower and field.

Under Decree 280, the IP model offers three distinct advantages:

1. Audit Readiness: If GACC requests an inspection or audit (now more clearly defined in Article 8 of the new decree), you can provide a complete digital history of the grain's journey, including specific FGIS quality data and APHIS phytosanitary records.

2. Simplified Renewals: Decree 280 introduces automatic 5-year renewals for many products—but only for those with a clean compliance record. IP grain minimizes the risk of "commingled contaminants," protecting your registration status.

3. Labeling Flexibility: The new decree allows more flexibility in using either your Chinese registration number or your U.S. authority-approved number on packaging. However, this flexibility requires absolute accuracy in your documentation—something only possible with a dedicated "Digital Gateway."

The Wigglesworth Strategy: Start Now

The implementation date is June 1, 2026. However, the application window for renewals and new registrations under the refined system is now 3 to 12 months before expiration.

At Wigglesworth, we aren't waiting for the deadline. We are already auditing our grower network and refining our "Gateway - Digital Passport" system to ensure that every category of food product we move is fully compliant with the transparency standards of Decree 280.