Exporting sesame to China: Decree 248 is not the rule any more.

What changed, in one paragraph

GACC Decree 248 no longer governs the registration of overseas food producers exporting to China. It was replaced by Decree 280, 《海关进口食品境外生产企业注册管理规定》, announced on 14 October 2025 and in force from 1 June 2026. Registrations already valid under Decree 248 carry over and do not need reapplication, but renewals and customs declarations now follow the new rules.

That alone puts most published guidance out of date. The second correction matters more for sesame specifically, and almost nothing published gets it right: raw edible sesame is not handled under the food-facility registration regime at all, and was not handled under it before June 2026 either.

Is GACC Decree 248 still in force?

No. Decree 248 was replaced by Decree 280 on 1 June 2026. Decree 280 was announced by the General Administration of Customs of China on 14 October 2025, and the USDA Foreign Agricultural Service published a full unofficial translation in GAIN report CH2025-0204, which states that the regulation "will enter into force on June 1, 2026, and will replace" Decree 248.

Existing valid registrations made under Decree 248 are carried over. What changed is the structure around them: risk-based registration types, a list-based registration mechanism, cold storage facilities brought into scope for the first time, a renewal window extended from 3 to 12 months before expiry, and new mandatory customs declaration fields.

Does raw sesame need CIFER food-facility registration for China?

On the evidence, no — raw edible sesame is a primary edible agricultural product, and Decree 280 explicitly carves those out of its own scope. Article 30 states that "the registration and management of overseas producers of primary edible agricultural products shall be separately formulated." Sesame is an oilseed, and oilseeds are among the primary agricultural products removed from the scope Decree 248 had covered.

The regime that does apply is entry animal and plant quarantine registration, not food-facility registration. GACC Announcement 27 of 2026, which implements Decree 280, points to the separate instrument: GACC Announcement 219 of 2025, issued 7 November 2025 and effective 15 December 2025. Its catalogue of agricultural products requiring official recommendation contains exactly one edible-sesame line, 1207409000101, 其他芝麻（不论是否破碎）（食用）.

⚠️ Read this as what it is. It says the CIFER route is the wrong route, which is a stronger and more useful statement than most guidance manages. It does not say there is no registration requirement, and it is not a substitute for confirming your own position with your customs broker or with GACC. Where a point below is inference rather than a read instrument, it says so.

Who applies — the exporter or the Nigerian government?

Not the exporter, and this is the part that surprises people who arrive expecting a CIFER-style self-service portal. Under the quarantine registration route, the competent authority of the exporting country must officially recommend the producer, processor or warehouse to GACC. For Nigeria that means NAQS and the Federal Ministry of Agriculture and Food Security. A Nigerian exporter cannot self-apply.

The registration is declared under licence category code 302, the entry animal and plant quarantine registration, rather than code 519, the food-facility certificate used for CIFER registrations. The published lists live on the GACC DAPQ pages at dzs.customs.gov.cn, not on the CIFER registered-food-facility list — which is why searching CIFER for a sesame supplier and finding nothing tells you very little.

On the Chinese side, the importer needs a quarantine permit, 进境动植物检疫许可证, before the trade contract is signed rather than after. That last point is consistent trade practice across sources but we have not read Order 177 directly, so treat it as likely rather than confirmed, and have your importer verify it.

What duty does Nigerian sesame pay entering China?

Zero, on the preferential rate, until 30 April 2028 — and this is verified against the tariff annex itself rather than a summary of it. Tariff Commission Announcement 2026 No. 5, 税委会公告2026年第5号, dated 28 April 2026, lists Nigeria (尼日利亚) among the countries in its 适用国别 schedule, and the annex sets a 0% preferential rate on both sesame lines: row 932, 12074010 种用芝麻 (sowing), and row 933, 12074090 非种用芝麻 (non-sowing) — the line commercial sesame ships under.

Two caveats worth more than the headline. The preferential rate runs 1 May 2026 to 30 April 2028, so it is dated and will need rechecking. And a preferential rate is claimed, not granted automatically: it depends on satisfying the rules of origin for the scheme, which is a separate question from the rate itself and one your importer's broker should confirm before it is written into a price.

Why does so much published guidance get this wrong?

Because Decree 248 was genuinely the headline instrument for several years, it generated an enormous amount of explainer content, and that content was never revised. A page written in 2023 describing CIFER registration under Decree 248 was reasonable then. It is wrong now on the instrument, and it was already pointing sesame exporters at the wrong regime.

The practical test for any China sesame page you read, including this one: does it name the instrument, its date, and where you can check it? If it says "Decree 248" with no date, it has not been revised since at least mid-2026. If it sends you to CIFER for raw sesame, it has not checked which regime primary agricultural products fall under.

What should a buyer or exporter actually do?

Five things, and the order matters:

1. 01Stop working from any source that presents Decree 248 as current — it was superseded on 1 June 2026
2. 02Establish whether your product is a primary edible agricultural product; for raw sesame the evidence says yes, which moves you out of the CIFER route entirely
3. 03For the quarantine route, engage NAQS and the Federal Ministry of Agriculture and Food Security, because the recommendation must come from them and cannot be self-filed
4. 04Have your Chinese importer obtain the quarantine permit before the contract is signed, not after
5. 05Confirm the rules of origin before writing the 0% preferential rate into a price — the rate is verified, your entitlement to claim it is a separate question

How current is this page?

The China regulatory position on this page was verified on 31 July 2026 and re-verified on 11 September 2026 against three independent sources: the USDA FAS GAIN translation of Decree 280 (CH2025-0204), the Chinese original of GACC Announcement 219 of 2025 and its catalogue, and independent regulatory trade press. The duty position was verified against the annex to 税委会公告2026年第5号 itself, not a summary — the extracted text is retained so the check is reproducible.

Two dates on this page will expire and are flagged deliberately rather than left to rot. The 0% preferential rate runs to 30 April 2028. GACC Announcement 219's catalogue was current to 28 April 2026 and is periodically updated. One item remains genuinely open: whether the quarantine permit requirement sits in Order 177 as trade practice suggests. We have not read that instrument, so this page says likely rather than confirmed.