压实食品委托生产安全责任

Core Viewpoint - The newly implemented "Food Commissioned Production Supervision Management Measures" by the State Administration for Market Regulation will take effect on December 1, 2026, establishing unified regulation for common production models like trademark licensing and OEM processing, thereby enhancing accountability among all parties involved in food commissioned production and reinforcing food safety standards [1][2]. Group 1: Regulatory Framework - The new regulations require both the commissioning party (brand owner) and the commissioned party (manufacturer) to have the necessary food safety management capabilities and to obtain production and business licenses or file for record [2]. - The regulations emphasize that the commissioning party must take primary responsibility for food safety, necessitating the establishment of systems, personnel allocation, and substantive supervision [2]. Group 2: Responsibilities and Accountability - The regulations clarify the responsibilities of both parties in key areas such as qualification verification, contract establishment, raw material control, labeling management, and inspection sampling, creating a robust accountability network [1][2]. - The commissioned party is required to strictly adhere to the permitted categories and production capacity when accepting commissions, effectively eliminating "incompetent commissioning" and "exceeding production limits" [2]. Group 3: Transparency and Enforcement - A reporting system for commissioned production is established, mandating that any changes in the commissioning relationship must be reported to regulatory authorities within a specified timeframe, ensuring transparency throughout the process [2]. - The regulations stipulate that product labels must clearly indicate the information of both parties involved, and introduce specific penalties for violations, along with a retrospective investigation mechanism to impose strict penalties for malicious actions [2].