2026年新规落地！食品“贴牌代工”监管新规带来五大剧变

Core Viewpoint - The new regulations on food production delegation will enhance accountability and transparency in the food industry, effective from December 1, 2026, ensuring that both the brand and the production party are responsible for food safety and production practices [2][27]. Group 1: Responsibility Allocation - The new regulations clarify that the brand (delegating party) holds overall responsibility for food safety, while the production party is responsible for the production process [9][11]. - Both parties must meet specific qualifications, with the brand required to supervise the production capabilities of the production party [9][12]. Group 2: Contractual Clarity - A written contract must be signed before any production delegation, detailing food safety-related matters, including qualifications, food names, and procurement methods [13][15]. - Contracts must be reported to local market supervision departments within 10 working days, ensuring regulatory oversight of production relationships [15]. Group 3: Supervision Obligations - The brand must conduct substantial supervision of the production party's operations, which can include on-site inspections and monitoring through various means [16][18]. - Any non-compliance by the production party must be addressed by the brand, which is also responsible for reporting to regulatory authorities [18][19]. Group 4: Transparency in Labeling - Pre-packaged foods produced under delegation must clearly label both the brand and production party's names, addresses, and contact information [20][22]. - This labeling requirement enhances product traceability and consumer awareness regarding the origins of their food [23][24]. Group 5: Inspection and Recall Protocols - The regulations strengthen inspection and recall procedures, mandating that the production party conduct product inspections and retain samples for a specified duration [25][27]. - In case of safety violations, both parties must act promptly to halt production and initiate recalls, marking the end of the era where brands could evade responsibility [27][28].