Since 1 June 2026, China registers overseas food manufacturers under GACC Decree 280, which replaced Decree 248, and applies import and export food safety rules under Decree 249. Vietnamese durian and fruit shipments face regular residue testing. By August 2026 GACC had approved 50 Vietnamese testing facilities for durian, and that capacity determines how long results take during peak season.
Against that background, the temperature record has moved from an internal document to a submitted one. Importers write it into the contract. Auditors ask for it during a facility inspection. And when there is a dispute about the condition of a consignment, it is the only evidence of what happened inside the container.
Why the requirement tightened
Chinese customs rules put the burden of proof on the exporter. Decree 280, which replaced Decree 248 on 1 June 2026, governs registration of overseas food production facilities. Decree 249 sets food safety responsibility for imported and exported food.
What they have in common is a shift from sampling the goods to auditing the system. The inspector is not only looking at the consignment in front of them, they are looking at how the business controls the whole process. A complete, continuous and verifiable temperature record is the cheapest way to demonstrate that.
What one failure costsA failed inspection can hold a facility out of the market until the issue is corrected and reviewed. Over that period, the cost of monitoring equipment for an entire season’s output stays well below the value of one month of lost shipping.
What counts as a complete record
A temperature record is treated as complete when it carries four groups of information. Missing any one of them, the record can still serve internally but is not enough to submit.
| Information | Requirement |
|---|---|
| Timing | Start and end of the journey, with the time zone stated |
| Logging interval | The gap between readings, fixed for the whole journey |
| Configured limits | The permitted range, set before departure and not changed en route |
| Excursions | Every excursion, with the time and duration of each |
| Device identity | Serial number, model, last calibration date and the calibrating body |
| Format | A non-editable PDF exported directly from the device or its software |
A record only carries weight when the reader cannot alter it, and when the reader knows which instrument produced it.
Choosing the device by product and route
Not every consignment needs the same instrument. Three factors decide: journey time, consignment value, and whether anyone needs to know the condition while the goods are still moving.
- Journeys under ten days, mid value: a single-use logger that plugs into USB and produces a PDF, packed with the load
- Long or multi-leg journeys, or high-value consignments: a real-time 4G unit with positioning and an immediate alarm on excursion
- Dry ice or deep-frozen goods: a purpose-built logger reading down to −85 °C
- Cold stores and reefers on fixed routes: reusable loggers on a scheduled recalibration cycle
For single-use devices, the cost per container is usually far below the cost of re-testing one detained consignment. That is why most exporters start with this group and move to real-time units only on the routes that matter most.
Common mistakes
Placing the device in the wrong position
The most frequent problem is not the instrument, it is where the instrument sits. A logger next to the container door or against the evaporator produces a curve that does not represent the temperature of the goods. Record the placement in the documentation and keep it identical between consignments so the data stays comparable.
Keeping a manual log alongside
When a facility runs both an automatic logger and a paper record, the two sets almost always disagree. An inspector will work from the less favourable one. Once the automatic logger is in use, retire the paper record and say so in the procedure.
Activating the device too late
The logger has to be started before loading, not after the doors close. The period when goods sit outside the chill waiting to be loaded is usually where the temperature rises fastest, and it is the period the customer cares about most.
An expired calibration certificate
A perfect record from an instrument whose calibration has lapsed carries no weight. Schedule calibration reminders against the serial number rather than against memory, and keep a copy of the certificate with the consignment file.
Preparing for an audit
Before an auditor arrives, review these five items. All of them can be done in half a day and all of them are what gets asked about most.
- Cold room temperature mapping, over at least 48 hours, still valid and with a clear conclusion
- A list of instruments in service, with serial numbers and last calibration dates
- A written procedure covering how devices are activated, placed and recovered
- Three to five recent consignment files, complete from end to end
- The record of a consignment that did have an excursion, with the corrective action attached
The last item is the one most often missed. A file showing no excursion at all across two years makes an auditor question whether the system is honest. One excursion, recorded, handled and closed to procedure, demonstrates that the system is working.
Elitech supplies single-use loggers, real-time 4G units and data management software to exporters in Vietnam, Thailand and the Philippines. Please contact us for a configuration recommendation based on your product and your shipping route.
