China SAMR Seeks Public Comment on Draft Amendment to the Food Safety Law

On October 10, 2026, China’s State Administration for Market Regulation (SAMR) published a draft amendment to the Food Safety Law of the People’s Republic of China for public review. The public consultation window will remain open until November 10, 2026.

The proposed update significantly expands the current law—increasing the total number of articles from 154 to 191, adding two new sections, and amending 93 existing articles.

Key changes in the draft include:

• Strengthening Primary Responsibility: Specifies the responsibilities and requirements for food production and operation enterprises, online food trading platforms, postal and express delivery companies, and other relevant entities.
• Strengthening Oversight in Key Areas: A dedicated section on “School Food Safety” has been added; a dedicated section on “Online Food Operations” has been added; and the primary responsibility for safety among cross-border e-commerce enterprises has been clarified.
• Optimizing the Food Safety Management System: Food additives and food-related products have been included in the scope of risk monitoring; infant and young children complementary foods have been incorporated into the regulatory framework for special foods; food labeling and commercial advertising have been standardized; and food inspection management has been tightened.
• Strengthening Smart Regulation: Promoting “Internet + Artificial Intelligence” regulation; requiring food production and operation enterprises to install surveillance systems at key risk points and connect them to regulatory agency systems; granting regulatory agencies the authority to conduct off-site inspections.
• Improving the Legal Liability System: Establishing differentiated penalty ranges based on the type of violation; implementing “personal liability for penalties”; adding penalty provisions corresponding to newly established obligations; and implementing food safety credit management and cross-departmental sanctions for dishonest conduct.

What Can CIRS Do for You

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan, and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services, from regulatory compliance, laboratory testing, and R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

The vast majority of members in CIRS Food Business Division have over 10 years of professional experience in food compliance, with more than 80% holding Master’s or Doctoral degrees in food-related disciplines. The CIRS toxicology expert team consists of 24 Chinese Certified Toxicologists (DCST), 2 American Board Certified Toxicologists (DABT), and 1 European Registered Toxicologist (ERT). CIRS has provided one-stop food compliance services to over 1,000 domestic and international food and related enterprises. Leveraging its technical expertise, diverse resources, and global network, the CIRS Food Business Division offers global food compliance services, including but not limited to:

• Health food registration and filing in China;
• Application for “Three New Foods (new food additives, new food raw materials and new food-related products” in China;
• U.S. GRAS, NDI, and CAP notifications;
• EU Novel Food, food additives, and food enzymes applications; and
• Application for new feed ingredients and feed additives in China, the U.S., and the EU.

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