Government regulation of food series: monitoring the intersection of "food" characters

LABEL： Agriculture and food , Compliance business , Corporate and M&A ,

In order to implement the "strictest supervision" among the "four strictest" requirements, China's food safety supervision is increasingly strengthened. In terms of regulatory system, the current regulatory authorities have formed a complete regulatory system by focusing on standard setting, risk assessment and monitoring, food industry access permits, emergency response, and investigation and punishment of food safety violations. From the perspective of enterprises, the food safety supervision and management department adopts a "parental" regulatory model, continuously refining inspection points, inspection content, and result disposal regulations to strictly control food safety.

During the production and operation process of food enterprises, it is inevitable that they will directly or indirectly be involved in law enforcement actions by regulatory authorities; Correspondingly, enterprises need to cooperate with relevant departments' supervision and management, properly respond to law enforcement investigations, maintain good food safety credit records, and effectively safeguard their legitimate rights and interests. As managers of food enterprises, especially those responsible for government relations and compliance, understanding the basic methods of law enforcement in the food industry is essential in order to clarify causal gains and losses and consider appropriate response measures in various investigations and enforcement.

Reading tip: This article aims to provide basic knowledge and key information on food industry regulation and law enforcement for food enterprises. Through this article, we will answer and focus on the following issues:

The regulatory and enforcement entities, enforcement content, and enforcement targets of the food industry.

Does food safety risk monitoring only involve overall industry risk monitoring, and will it lead to direct penalties for enterprises?

How to determine whether the food produced and operated by the enterprise falls within the scope of monitoring and spot checks, and what are the methods and frequencies of monitoring and spot checks?

Which food companies are the key targets for regulatory inspections of premises? What behaviors can lead to flight inspections of food companies?

On the basis of briefly describing the law enforcement and regulatory system of the food industry, we will provide a detailed introduction to the two major direct regulatory scenarios of food sampling and site inspection, and share several practical suggestions on how food enterprises can correctly cooperate and respond to regulatory enforcement.
1、 Overview of Food Law Enforcement and Supervision

Before discussing how to cooperate and respond to law enforcement and supervision, food companies need to first understand the specific division of labor and responsibilities of each regulatory authority, in order to clarify the law enforcement agencies and specific law enforcement content in different regulatory scenarios. Specifically, we will discuss from three aspects: regulatory objects, regulatory subjects, and regulatory content:
1. Regulatory object

The scope of food safety supervision is very broad. Generally speaking, enterprises engaged in production and operation activities directly or indirectly related to any food in China belong to the scope of supervision. According to the Food Safety Law of the People's Republic of China (the "Food Safety Law"), food refers to various finished products and raw materials for human consumption or drinking, as well as items that are traditionally both food and traditional Chinese medicinal materials (but do not include items for therapeutic purposes). On this basis, Article 2 of the Food Safety Law stipulates that the following activities of enterprises fall within the scope of food safety supervision:

Food production, processing, storage, and transportation;

Food sales and catering services;

Production and operation of food additives;

Food producers and operators use food additives and food related products;

Production and operation of packaging materials, containers, detergents, disinfectants used for food, and tools and equipment used for food production and operation;

It should be clarified that the regulation of unprocessed products ("primary agricultural products") obtained from agricultural activities such as planting, animal husbandry, and fishing still falls within the scope of broad food safety regulation. Among them, the quality and safety management of primary agricultural products is subject to the constraints of the Agricultural Product Quality and Safety Law of the People's Republic of China, while the market sales, quality standard formulation, and safety information disclosure of primary agricultural products must comply with the Food Safety Law.
2. Regulatory body

The main body of food safety supervision involves multiple and different levels of administrative agencies. Overall, the food safety committee established by the first level government is responsible for overall situation analysis and work deployment; The Health Commission is responsible for risk assessment and standard setting work; The agricultural and rural departments are mainly responsible for the supervision and management of the quality of primary agricultural products; The market supervision and management department is responsible for various practical operational aspects involved in the food production and operation process, such as licensing systems, daily sampling, inspection, and illegal disposal, as follows:

           
3. Regulatory content

In a broad sense, government regulation in the field of food safety covers many aspects. This includes the pre establishment of national food safety standards, administrative licensing for admission, risk monitoring and assessment during the process, administrative supervision and law enforcement, as well as post emergency response and administrative penalties. Based on the Food Safety Law, the regulatory scenarios that food production enterprises may face are briefly summarized as follows:

           

*The above scenarios are not exhaustive, and the content of segmented scenarios such as food labeling and labeling management, advertising and marketing is omitted here.

The above regulatory scenarios do not exist independently, and different scenarios are interrelated and influence each other. For example, the results of food safety risk assessment and monitoring will affect the updating and iteration of national food safety standards, and the iterated standards can be incorporated into administrative licensing review conditions. For example, the "National Food Safety Standard - Limits of Contaminants in Food" (GB 2762-2022), which officially came into effect on June 30, 2023, was revised based on relevant risk monitoring and risk assessment results [5], and this standard has been cited as one of the inspection standards for trial food in the open production license review elements of roasted coffee in Shanghai. For example, the aforementioned risk assessment and monitoring results will be used by regulators to determine the focus, methods, and frequency of supervision and management, and to implement risk grading management.

It can be clearly perceived that the current government regulation of the food industry is becoming increasingly systematic. The segmented food industry in which food enterprises operate, the overall risk assessment of the industry, and the compliance of the enterprises themselves will all affect the regulatory situation faced by the enterprises. In many regulatory scenarios, food sampling and venue inspections involve direct contact between enterprises and regulators, and can directly affect the evaluation of enterprise food safety compliance by regulators, often causing significant pressure on enterprises. In order to help enterprises correctly respond to and cooperate with such regulatory enforcement, this article will focus on the detailed introduction of food safety sampling (monitoring) and venue inspections.
2、 Food safety monitoring and sampling

The monitoring and sampling of food safety include risk monitoring, evaluative sampling, and supervisory sampling, targeting food products produced and operated by food enterprises. When facing food inspections, relevant enterprises should first clarify the nature of this inspection in order to respond appropriately and targetedly, as follows:
1. Risk monitoring

This type of risk monitoring work is carried out by sampling and testing food at pre-set food safety risk monitoring points, in order to comprehensively evaluate and grasp the level of food safety risks in the region. It is usually organized and implemented by the health administrative department ("Health Commission") in conjunction with customs, market supervision, grain and material reserve bureaus, and other departments. It should be noted that although risk monitoring is of a risk prevention and control nature, it can indeed have a direct impact on enterprises in practice, including the possibility of food recalls, further administrative investigations, or penalties.

The primary purpose of this type of risk monitoring is not to directly discover and verify the illegal behavior of enterprises, and the actual sampling personnel are not law enforcement personnel, but various monitoring technology institutions (such as local disease prevention and control centers and medical institutions, etc.). Their specific work content is to carry out national and provincial routine and special monitoring of chemical pollutants and harmful factors, microorganisms and their pathogenic factors in the food (mainly bulk daily consumer goods) operated in the directory places. This type of technical institution will report and report the relevant risk monitoring results to support food safety risk assessment, food safety standard revision, food safety risk warning and communication, and other related work. The risk monitoring results are usually not individually communicated to the monitored enterprises. Only when the monitoring results indicate the existence of food safety hazards and the municipal supervision department confirms the necessity of notification, will the relevant enterprises receive the notification.

Food producers and operators who receive notifications should immediately conduct self inspections. If they find that the food does not meet food safety standards or there is evidence that it may harm human health, they should stop production and operation, implement food recalls, and report relevant situations. If food enterprises do not cooperate, they will be ordered to fulfill relevant obligations, and the legal representative or main person in charge will be held accountable for their actions. In practice, it is important to note that even if a company's products do not violate current mandatory safety standards, they may still face administrative enforcement measures such as recalls, administrative investigations, and rectification due to risk monitoring results (such as being deemed to have potential safety hazards).

           

The monitoring results of food pollutants and harmful factors in Shanghai in 2023 are excerpted from the "2024 Shanghai Food Safety Status Report"

For food production and operation enterprises of bulk daily consumer goods, especially key places such as fresh supermarkets and agricultural markets, they can cooperate and respond to regulatory risk monitoring work from the following aspects:

(1) Pay close attention to the testing and sampling roll call records and related monitoring plans released by local county-level and above health commissions and municipal supervision departments to understand whether they belong to the monitoring scope, as well as the types, varieties, sampling processes, monitoring projects, and monitoring months of the food to be tested, in order to have a clear understanding;

(2) Strengthen relevant food safety supervision work, regularly carry out self testing and self-examination, and maintain a high level of food safety for oneself; Pay attention to the monitoring results released in the local area, and carry out targeted compliance management for the identified categories of unqualified food. Specific measures such as increasing self testing frequency, strict procurement inspection, and strengthening supplier control can be considered based on one's own situation.

(3) When relevant monitoring agencies conduct door-to-door sampling, cooperate with sampling and provide relevant convenience, do not refuse, obstruct or interfere with their risk monitoring work, such as restricting sampling personnel from entering certain areas for sampling, guiding or interfering with sampling personnel's selection of sample types and quantities, etc.

(4) If a situation is identified as potentially endangering food safety, it needs to be highly valued, and the criteria for such identification should be analyzed. In particular, it should be clarified whether the product violates the standards determined by local authorities based on expert identification or may trigger national safety standards. If necessary, it is recommended to involve external third-party professional organizations in the investigation to properly handle subsequent investigations and whether they involve subsequent rectification.
2. Supervision sampling and evaluative sampling

Supervision sampling refers to the sampling, inspection, re inspection, and handling activities of food organizations carried out by market supervision and management departments in accordance with legal procedures and food safety standards, with the purpose of identifying risks. The inspection conclusions will serve as the basis for administrative penalties imposed on the involved enterprises by the regulatory authorities. Evaluation sampling is a sampling activity guided by the assessment of the overall safety status of food, and its conclusions will serve as the basis for the evaluation of food safety management by higher-level regulators on lower level regulators. It should be noted that in terms of evaluative sampling, although its main purpose is to assess whether the relevant food safety level meets the government's expected regulatory goals, regulators can still verify and dispose of problematic enterprises based on the sampling results [8]. In other words, the inspection conclusions obtained from supervisory sampling and evaluative sampling can both serve as the basis for administrative penalties.

In terms of sampling plans, the State Administration of Market Regulation formulates a national annual plan for food safety sampling and inspection based on the needs of food safety supervision work, while market supervision and management departments at or above the county level formulate specific work plans based on the annual plan formulated by higher-level supervision and combined with actual situations. The work plan and work program will specify the food varieties to be sampled for inspection, the sampling process, and other specific contents, and will also explain the sampling focus [9].

In terms of sampling procedures, the municipal supervision department can conduct sampling on its own or entrust inspection agencies to conduct sampling, and food enterprises will not be notified in advance. There shall be no less than two sampling personnel, and food safety sampling activities during case inspection and accident investigation shall be carried out or accompanied by food safety administrative law enforcement personnel. After the sampling personnel arrive at the location of the food enterprise, they will present the "Sampling Inspection Notice" and identification documents. Then, they will randomly select samples from the food enterprise's business premises, warehouse, and the finished product warehouse of the food producer (self provided samples are not accepted), and record traceable information such as the business license and permit of the sampled food producer and operator. Sampling personnel, in addition to purchasing the samples themselves, will also take photos or videos of the sampling site, storage environment, and sample information for on-site sampling; For online shopping sampling, the unpacking process, delivery packaging, sample packaging, sample storage and transportation conditions, etc. will also be inspected and documented as evidence for subsequent law enforcement against unqualified food.

For food production and operation enterprises, in practice, they can prepare, cooperate and respond to the sampling work of the municipal supervision department from multiple aspects. After receiving the conclusion of unqualified food, they can make corresponding targeted treatments according to their own situation, as follows:

(1) Incorporate monitoring of regulatory developments into the daily work plan of the enterprise. The food safety department of food production and operation enterprises should closely monitor key information such as sampling plans, schedules, and special actions issued by regulatory authorities, and guide the daily food safety management priorities of the enterprises accordingly; In addition, compliance training should be provided to frontline managers and management of production and business premises, and dedicated personnel should be assigned to coordinate and respond to government inspection activities.

           

2023 Jing'an District Food Safety Supervision and Sampling Work Plan

(2) When faced with regulatory personnel's sampling activities, cooperate but do not intervene, and keep complete sampling records, especially detailed records of the relevant conditions, basic information, production batch number, sampling method, sampling content, etc. of the sampled products, for subsequent internal investigation and comparison within the enterprise. If the sampling activities violate relevant sampling standards, the enterprise can remind the sampling personnel on site and keep records. If there are objections to the sampling process, the enterprise may submit a written application and relevant supporting materials to the municipal supervision department that implements supervision and sampling within 7 working days after the sampling is completed.

(3) After the sampling inspection is completed, if the enterprise receives the "Notice of Sampling Inspection Results" and learns that the food is unqualified, it is recommended to establish a relevant working group and take corresponding measures according to the situation:

Immediately seal off unqualified food, suspend production and operation of unqualified food, notify relevant producers, operators and consumers, recall unqualified food that has been put on the market for sale and other risk control measures, investigate the reasons for unqualified food and make rectification, report the handling situation to the local market supervision and management department in a timely manner, actively cooperate with the investigation and handling of the market supervision and management department, and shall not refuse or evade. In addition, relevant information on non-conforming products should be prominently displayed at the sampled business premises. For information on food recalls, please refer to the article "It's Not Too Late to Make Up for the Lost Sheep - A Detailed Discussion on Food Recalls".

Rapid internal evaluation, after discussion by the working group, if the inspection conclusion is questionable, a written re inspection application can be submitted to the municipal supervision department or its higher-level supervision department that implements supervision and sampling within 7 working days from the date of receiving the inspection conclusion. However, if the inspection conclusion is that the microbiological indicators are unqualified or the re inspection backup samples exceed the shelf life, re inspection cannot be carried out. In practice, for edible agricultural products such as fresh produce that are not suitable for storage, sampling personnel usually use the "rapid detection" method for inspection [11]. In this case, relevant enterprises can apply for re inspection within 4 hours, and the re inspection will be routine laboratory inspection, without using rapid methods.

If the working group considers that there are doubts about the authenticity of the sample, the inspection method, and the application of standards, the enterprise may submit a written application to the municipal supervision department that organizes and implements supervision and sampling within 7 working days from the date of receiving the notification of the unqualified conclusion, and submit relevant supporting materials.

In terms of administrative responsibility, if an enterprise refuses, obstructs, or interferes with food safety sampling inspection, risk monitoring, and investigation without justifiable reasons, it will face orders to suspend production or business and fines of not less than 2000 yuan but not more than 50000 yuan. If the circumstances are serious, the license will be revoked; If the inspection conclusion is unqualified and the enterprise refuses to recall or stop operating, it will face confiscation of illegal gains, confiscation of illegal items, and a fine of up to 20 times the maximum value of the goods. In addition, for the specific unqualified situation of the sampled food, it will also face administrative responsibilities under Articles 123, 124, and 125 of the Food Safety Law, and in serious cases, it will also face criminal accountability.
3、 Venue inspection

In addition to food safety monitoring and sampling for food products themselves, enterprises may also face inspections by regulatory agencies on food production and operation sites. In order to effectively cooperate with supervision, enterprises should be familiar with the specific operation mode of government supervision and inspection in advance, including the regulatory body, inspection methods, and inspection content, which are described as follows:

At the level of inspection subject, according to the "Measures for the Supervision and Inspection of Food Production and Operation" ("Supervision and Inspection Measures"), the power of food production supervision and inspection belongs to the market supervision and management department. Among them, the State Administration for Market Regulation is responsible for supervising and guiding the national food production and operation supervision and inspection work, while the provincial market supervision and management departments are responsible for supervising and guiding the specific supervision and inspection work within their respective administrative regions. The specific supervision and inspection work is usually carried out by the market supervision and management departments at the city and county levels. As an exception, market supervision and management departments at or above the city level may directly conduct random supervision and inspection of enterprises under the daily supervision of market supervision and management departments at the city and county levels when necessary, or organize lower level market supervision and management departments to conduct off-site inspections.

At the level of inspection methods, according to the "Supervision and Inspection Measures", the inspection methods for food enterprises by regulators are divided into three types: daily inspection, flight inspection, and system inspection. Specifically:

Daily inspection refers to the routine inspections conducted by the municipal and county-level market supervision and management departments on food producers and operators within their administrative regions in accordance with the annual food production and operation supervision and inspection plan.

Flight inspection refers to the supervision and inspection conducted by market supervision and management departments on food producers and operators without prior notice, based on the needs of supervision and management work and problem clues.

System inspection refers to the systematic supervision and inspection conducted by market supervision and management departments, guided by risk prevention and control, on the implementation of quality management systems in special food, high-risk bulk food production enterprises, and large-scale food operation enterprises in accordance with the law.

Due to differences in the business format, concentration level, and food consumption composition of food enterprises in different regions, the characteristics of food safety risks also vary. Therefore, there are certain differences in the proportion and implementation methods of inspection methods faced by food enterprises in different regions. The food safety supervision and inspection plan, food safety risk grading management measures, etc. issued by the provincial market supervision and management department where food enterprises are located usually specify the applicable objects and frequencies of daily inspections, flight inspections, and system inspections in the local area. For example:

In terms of daily inspections, taking Shanghai as an example, the "Management Measures for Food Safety Risk Grading and Credit Classification of Food Production Enterprises in Shanghai" ("Shanghai Risk Grading Measures") stipulate that the frequency, content, and methods of inspections mainly depend on the food safety credit risk level of the food enterprise. For example, food production enterprises with a food safety credit risk level of D are generally supervised and inspected at least three times a year, and full project supervision and inspection will be implemented during the inspection. For example, the "2024 Food Production Supervision and Inspection Plan" of Chaozhou Municipal Supervision Bureau stipulates that the daily supervision and inspection of each health food production enterprise should be no less than 2 times a year, and the supervision and inspection of infant formula milk powder production enterprises should be no less than 4 times a year.

In terms of flight inspections, regulatory inspections of enterprises are usually carried out due to the existence of risk situations within the enterprise itself. According to the Shanghai Risk Grading Measures, when a food production enterprise encounters a risk warning situation, the market supervision and management department shall organize a flight inspection within 10 working days, including eight situations where the enterprise is reported and verified more than three times within the year of the level determination. In addition, in the flight inspection plans of various regions, there is also a practice of framing a group of high-risk enterprises and conducting random flight inspections among them. For example, in the flight inspection activity of Pudong Supervision Bureau in Shanghai in August 2024, the bureau collected food safety risk and credit information data of enterprises based on the Pudong New Area "Traceability+" food production enterprise online supervision platform, and framed the scope of flight inspection enterprises through summary analysis, and randomly selected flight inspection objects from them.

In terms of system inspection, due to the high inherent food safety risks in the segmented field where the enterprise is located, it is necessary for supervision to implement system inspections on the operation of the quality management system of such enterprises. The system inspection is mainly applicable to health food production enterprises, special food production enterprises such as infant formula food, and large food sales enterprises. In regulatory practice, market supervision and management departments can also conduct more detailed system inspections on food production enterprises by entrusting third-party certification agencies and introducing third-party professional organizations. At present, there are no specific regulations on the frequency of system inspections in various regions. Usually, after the deployment of relevant work by the national and provincial market supervision and management departments, the market supervision and management departments of each city and county will implement system inspections for all relevant enterprises within their jurisdiction.

In terms of inspection content, according to Article 15 of the Supervision and Inspection Measures, the key points of supervision and inspection in the food production process include the qualifications of food producers, production environmental conditions, procurement inspection, production process control, product inspection, storage and delivery control, management of unqualified food and food recall, labeling and instructions, food safety self-examination, management of employees, information recording and tracing, and disposal of food safety accidents. The State Administration for Market Regulation has further formulated the general "Key Points Table for Supervision and Inspection of Food Production and Operation" and the "Record Table for Supervision and Inspection Results of Food Production and Operation", which list the specific inspection key items, general items, and specialized items of the market supervision and management department under different inspection methods. Overall, the content of daily inspections focuses on the qualification and basic production status of food production enterprises, and inspection terms will be selected based on the production and product characteristics of the food enterprises; Flight inspection usually determines the focus of inspection based on the situation, while system inspection focuses on the operation of the enterprise's quality management system. Regarding food production and operation process management, good production practices, and other related content, please pay attention to the follow-up articles in this series.

When food companies face regulatory on-site inspections or prepare for pre informed on-site inspections, they first need to avoid the "cat and mouse mentality" and abandon the misconception that responding to regulation is equivalent to "avoiding" regulation. Actively cooperating with regulatory on-site inspections can not only help companies improve compliance credibility and save compliance costs, but also effectively save regulatory resources of relevant departments, reflecting the company's sense of social responsibility. In practice, enterprises often engage in improper behavior when facing on-site inspections by regulators, with refusal to cooperate with investigations being the most common. Typical examples include refusing law enforcement personnel to conduct inspections, providing false information in an attempt to evade supervision, and using excuses such as "the person in charge is not available" and "no authority". In fact, both management and frontline employees have a legal obligation to cooperate with supervision in conducting on-site inspections. Refusing to cooperate with on-site inspections is a red line behavior under government supervision. According to Article 49 of the Supervision and Inspection Measures, if a food producer or operator refuses, obstructs, or interferes with the supervision and inspection conducted by the market supervision and management department [12], the relevant competent department shall order them to suspend production or business according to their respective responsibilities, and impose a fine of not less than 2000 yuan but not more than 50000 yuan; If the circumstances are serious, the license shall be revoked; If it constitutes a violation of public security management, the public security organs shall impose public security management penalties in accordance with the law.

In order to better cooperate with on-site regulatory inspections, food production enterprises can carry out work from the following aspects:

(1) Pay attention to the acquisition of regulatory information. Food production enterprises should closely monitor the food supervision and inspection plans issued by the country and their own regions, maintain close communication with regulators, and make advance judgments on the inspection methods, contents, and frequencies that may be adopted by current regulators; Food production enterprises can refer to the on-site inspection situation of similar enterprises, conduct self sorting and rectification of possible inspection items and compliance points in advance, maintain a good compliance level, and have a clear understanding of possible inspections.

(2) Pay attention to internal compliance training within the enterprise. Internal government relations and legal department personnel should regularly provide compliance training to frontline business personnel, teaching them the correct coping methods when facing law enforcement interviews. Generally speaking, no personnel shall sign any documents provided by regulatory authorities, provide irrelevant information to law enforcement personnel, or express subjective or speculative opinions, whether oral or written, without confirmation from management or external lawyers.

(3) A dedicated person is responsible for government regulatory work. Enterprises may designate a middle to senior management personnel ("designated specialist") specifically responsible for liaising and liaising with regulatory authorities. Such designated specialist should be an employee who understands the business of the enterprise and is familiar with the key points and practices of food production compliance. During the on-site government inspection process, the designated commissioner should accompany law enforcement personnel throughout the process, introduce the basic overview and past compliance situation of the enterprise, and be specifically responsible for answering relevant questions from law enforcement inspectors; If regulatory requirements require employees from other companies to answer, authorization should be granted by the designated specialist; If regulatory requirements require individual questioning of relevant employees, then on the basis of authorization, the questioned employees should be required to provide feedback on their answers to the relevant questions and keep relevant records.

(4) Actively cooperate with law enforcement. During the on-site inspection process, the enterprise should first verify the identity of the law enforcement personnel in a friendly manner, and clarify the nature, purpose, and scope of this inspection. Subsequently, open up food production and operation sites, cooperate with law enforcement personnel to inspect various sites and compliance points in the order required, provide relevant contracts, receipts, account books, and other relevant information such as previous supervision and inspection results and rectification situations, and assist in on-site inspections and sampling inspections of production and operation sites; When responding to questions from law enforcement personnel, one should be truthful, concise, and keep relevant records; For written proof documents required by law enforcement personnel, a list of documents should be made and copies of the documents should be kept on the basis of timely provision.

(5) Pay attention to collecting and fixing positive factors, and strive for favorable recognition. During the on-site inspection process, the enterprise records the complete inspection process, paying particular attention to backing up and preserving production records, important documents, and tangible objects involved in the inspection process; When law enforcement personnel make requests beyond the scope of supervision and inspection, kindly raise and inquire about the basis (but do not interfere with law enforcement); If there are any doubts, communicate and explain them thoroughly based on facts, and strive for favorable recognition. For example, equipment cleaning records are stored in an immutable electronic data format, and if there are no written records, they should be clarified in a timely manner.

(6) Actively implement rectification measures after inspection. For the rectification items raised by on-site inspectors, if the enterprise can rectify them on the spot, it should rectify them on site; Enterprises should actively implement and promptly report to the municipal supervision department after the deadline for rectification. If an enterprise is ordered to suspend production or business, it shall immediately cease production, actively rectify and cooperate with the subsequent investigation of supervision.

(7) Timely introduce external institutions to intervene. When a company receives an inspection notice or faces a sudden inspection, it is recommended to promptly contact an external lawyer to assess the nature, scope, and development of the inspection, and determine whether and to what extent the external lawyer should intervene.
epilogue

Compared to various post incident coping strategies, food companies should focus more on cultivating the "way" of responding to government regulation, that is, strictly grasping daily food safety management work, formulating various food safety systems on the basis of complying with food safety regulations, and strictly implementing and recording them. A good level of food safety compliance, comprehensive government regulatory cooperation and response plans, and well-trained specialized personnel can help enterprises cope calmly in various on-site inspection scenarios, and in a broad sense of brand image, social responsibility, etc., help enterprises achieve greater development.