On December 1, 2026, the Food Recall Management Measures (食品召回管理办法), State Administration for Market Regulation (SAMR, 国家市场监督管理总局) Order No. 122 (国家市场监督管理总局令第122号), take effect in mainland China.
Mainland China food producers and food traders, principals commissioning OEM food production for the mainland China market, third-party platforms selling food online into mainland China, and food market operators, booth lessors and fair organizers in mainland China must, by December 1, 2026, have a recall system that stops unsafe food at once, starts a Level I, II or III recall within 24, 36 or 48 hours of discovery, finishes it within 10, 20 or 30 days of the recall plan, reports progress and closure, and keeps processing and destruction records, or a market regulator at municipal level or above may issue a compulsory recall order (责令召回) where the operator does not recall.
- Deadline: December 1, 2026, when the measures take effect and these obligations become due
- Who: Mainland China food producers and traders, OEM principals, online food platforms, and market, booth and fair organizers
- What: Stop unsafe food, run the graded start and finish clocks, report progress and closure, process or destroy recalled food, and halt sales and post the notice where Articles 17 to 19 apply
- Otherwise: A market regulator at municipal level or above may issue a compulsory recall order (责令召回) where the operator does not recall
- Official source: SAMR Order No. 122, Food Recall Management Measures
What is due on December 1, 2026
Level I is the food recall grade for a risk of acute or severe harm to health, or of death. Level II covers chronic or general harm to health, and Level III covers other non-conformity. SAMR promulgated Order No. 122 on January 27, 2026, replacing the 2020 version, and it takes effect on December 1, 2026. Discovery of food that fails safety standards or may endanger health then requires a stop and a recall (Articles 3, 4 and 8). The table is Articles 11, 15, 10 and 24. No public notice is required when no product reached consumers.
| Grade | Start after discovery | Finish after the plan | Progress reports |
|---|---|---|---|
| Level I | 24 hours | 10 days | Daily |
| Level II | 36 hours | 20 days | Every 5 days |
| Level III | 48 hours | 30 days | Every 10 days |
Who is covered
Coverage follows the activity on the mainland China market: producers and traders run the recall, the OEM principal implements it, and platforms, market operators, booth lessors and fair organizers halt sales and post the notice. Obsidian tracks 5 regulatory texts, in force, amended or in preparation, under the Food Safety Law of the PRC (食品安全法) in China, as of November 2026.
What to do before December 1, 2026
- Grade each line as Level I, II or III on the health-harm tests.
- Stop production or sale and start the recall when food fails safety standards or may endanger health (Articles 3, 4 and 8).
- Start within 24, 36 or 48 hours, with the plan, notifications and public notice (Article 11).
- Finish within 10, 20 or 30 days of plan submission, or only with regulator consent to extend (Article 15).
- Report the plan before launch, progress by level, and closure within 5 days (Articles 10 and 24).
- Process or destroy recalled food, notify the county regulator before destruction, and keep records at least 6 months after expiry and no less than 2 years (Articles 21 and 23).
- On commissioned production (委托生产), the principal (委托方) runs the recall and the manufacturer (受托方) cooperates. Platforms and organizers stop sales and post the notice (Articles 8, 17, 18 and 19).
What happens otherwise
Where the operator does not recall, a market regulator at municipal level or above may issue a compulsory recall order (责令召回). SAMR and provincial market regulation departments enforce. Continuous per-jurisdiction monitoring surfaces this kind of graded-recall rule when the official text is published.
