Q.01

How does food safety monitoring work?

Food safety monitoring is a cycle. Authorities plan risk-based checks and sampling, test samples in accredited labs against legal limits, act on what fails, report the results each year, and share alerts with other countries. The EU sets this out in the most detail, under the Official Controls Regulation (EU) 2017/625 and the pesticide residues regulation (EC) No 396/2005. I've used GB, the US FDA and WHO's INFOSAN network to show how the same pieces work elsewhere.

1. Who and what is covered (EU)

  • Regulation 2017/625 covers official controls on food safety, integrity and wholesomeness at any stage of production, processing and distribution. It also covers food contact materials, feed, GMOs, animal health and welfare, plant health, pesticides, organic production and protected designations [1].

2. Risk-based planning

  • Authorities "shall perform official controls on all operators regularly, on a risk basis and with appropriate frequency" [2]. Frequency depends on:
    • the product and the activity;
    • the operator's past compliance record;
    • how reliable the operator's own checks are;
    • any sign of fraud or misleading practices.
  • Controls are carried out without prior notice, except where notice is necessary and duly justified [2].
  • Each Member State shall run its controls under a multi-annual national control plan (MANCP), coordinated by a single designated body [3].
  • Pesticides have their own layer:
    • The Commission prepares a coordinated EU control programme, adopted and updated every year [4].
    • Each Member State runs a risk-based national programme. It specifies which products to sample, how many samples, which pesticides to test for, and how much each product weighs in the national diet [5].

3. Inspection and sampling

  • Inspectors can use any of these methods [6]:
    • reviewing the operator's own checks;
    • inspecting premises and goods;
    • checking hygiene and HACCP procedures;
    • checking traceability records and labels;
    • interviewing staff;
    • sampling and analysis;
    • auditing the operator.
  • Sampling and analysis methods shall follow EU rules, or recognised standards such as CEN where there are none. Samples shall be taken, handled and labelled so that the results hold up legally, scientifically and technically [7].
  • Operators have a right to a second expert opinion at their own expense. Asking for one does not delay any urgent action to contain a risk [8].

4. Laboratories

  • Official laboratories shall be designated in writing, act impartially, and operate under EN ISO/IEC 17025 with accreditation from a national accreditation body [9].

5. Imports

  • Every consignment of certain goods shall be checked at the border control post where it first enters the EU. These include products of animal origin, composite products, and goods under temporary increased controls or emergency measures [10].

6. Enforcement when something fails

  • Authorities shall find out where the problem came from and how far it goes, and make the operator fix it. Measures available include [11]:
    • correcting labels or informing consumers;
    • restricting or banning sale, movement, import or export;
    • more frequent official controls;
    • recall, withdrawal or destruction of goods;
    • closing the business or suspending its approval.
  • The operator pays the costs [11].

7. Reporting and sharing information

  • Each Member State reports to the Commission by 31 August every year. The report covers control outcomes, the number and type of non-compliances, and the enforcement taken [12].
  • Pesticide residue results go to the Commission, EFSA and the other Member States by 31 August. They include detection limits, laboratory proficiency testing and accreditation status [13].
  • Member States shall publish all their residue results online each year. Where limits are exceeded, they may name the retailers, traders or producers [5].
  • EFSA then publishes an annual report on pesticide residues. It analyses why limits were exceeded and the chronic and acute risks to consumers [14].
  • Member States give each other administrative assistance on cases affecting more than one country [15]. Control data is exchanged through IMSOC, the EU's shared information system for official controls [16].

Great Britain (Food Safety Act 1990)

  • Authorised officers may buy or take samples of food, food sources and food contact materials (s.29) [17]. They have rights of entry and may inspect and seize records (s.32) [18].
  • They can serve improvement notices, which give at least 14 days to comply; failing to comply is an offence (s.10) [19].
  • Where there is an imminent risk to health, they can serve emergency prohibition notices. These lapse after three days unless the authority applies to a court for an order (s.12) [20].

United States (FDA pesticide residue programme)

  • In FY2024 the FDA analysed 3,834 samples: 3,528 human foods (893 domestic, 2,635 imported) and 306 animal foods [21].
  • The programme targets products with a history of violations, or suspected of them. The violation rate for imported human foods was 15.6%, against 1.8% for domestic foods. Commodities with high violation rates are flagged for more sampling [22].

International (WHO INFOSAN)

  • Countries share incidents through national emergency contact points and focal points. In Q4 2023 the INFOSAN Secretariat handled 51 incidents. 41% were reported through the EU's Rapid Alert System for Food and Feed (RASFF), 40% by INFOSAN members and 19% through WHO channels. The example in that quarter was lead in cinnamon applesauce, recalled in the US and traced back with Ecuador [23].

The pesticide residue articles above are from Regulation 396/2005 as originally adopted; I did not check them against later amendments.

Approach: I read the consolidated EU Official Controls Regulation (2017/625, edition dated 5 January 2025), the EU pesticide residues regulation (396/2005), the revised GB Food Safety Act 1990, the FDA's FY2024 pesticide residue monitoring report and the WHO INFOSAN quarterly summaries. I did not open the EU General Food Law regulation, which sets up RASFF, so RASFF appears here only as INFOSAN describes it.

If you name a jurisdiction or a hazard (pesticides, contaminants, microbiology, imports), I can go into that part in detail.

Q.02

How does China compare with the US?

China and the US both run risk-based food monitoring, but they organise it differently. China works under one statute, the Food Safety Law. It keeps two tracks apart: a public-health risk-monitoring system run by the health authority and its CDC network, and enforcement sampling by market regulators that must be published. The US works through the Federal Food, Drug, and Cosmetic Act (FDCA) as amended by FSMA in 2011. There the FDA enforces limits that other agencies set, the statute fixes minimum inspection frequencies, and much of the prevention duty sits with operators and importers.

Legal basis

  • China: the Food Safety Law of 2009, revised in 2015 and last amended on 12 September 2025 (MOFCOM text). That amendment took effect on 1 December 2025 (gov.cn, Presidential Order 56). It does two things (Jiangmen government notice):
    • it requires a permit (准运证) for bulk road transport of key liquid foods;
    • it brings infant-formula liquid milk under the same registration rules as infant formula powder (Arts 81, 82 and 124).
  • US: the FDCA, with the inspection-targeting section added by Pub. L. 111-353 on 4 January 2011 [24].

Monitoring vs. enforcement

China's law treats these as two separate systems:

  • Risk monitoring (Art. 14): "国家建立食品安全风险监测制度" (the state establishes a food safety risk monitoring system). It covers foodborne disease, food contamination and harmful factors in food (MOFCOM text).
    • The health authority, with other State Council departments, issues an annual national monitoring plan. The 2012 plan was issued jointly by six ministries [25].
    • The work is split into separate manuals for chemical contaminants, foodborne pathogens, foodborne disease and radioactivity [26].
    • CFSA leads the network. Provincial CDCs are the core, with prefecture CDCs and county CDCs below them [27].
    • Scale in 2011 [27]:
      • 1,196 county-level contaminant monitoring points;
      • 405 technical institutions, analysing 155,500 samples;
      • 465 sentinel medical institutions for suspected foodborne illness;
      • foodborne disease reporting across 2,854 CDCs;
      • a start on building the ChinaFoodNet active surveillance network.
    • The results feed risk assessment and standard-setting, and point enforcement towards priority areas [27].
  • Enforcement sampling (Art. 87): food safety regulators at county level and above "应当" (shall) sample and test food on a regular or irregular basis, publish the results, and "不得免检" (may not exempt any food from inspection). An operator who disputes a result can ask for a re-test within seven working days (Art. 88) (MOFCOM text).

The US does not divide things this way. EPA sets pesticide tolerances, and the FDA enforces them on domestic food in interstate commerce and on imports. USDA's FSIS covers meat, poultry, Siluriformes fish and certain egg products [28]. The FDA's pesticide work has three parts [28]:

  • regulatory monitoring for about 780 pesticides and selected industrial compounds;
  • focused sampling surveys;
  • the Total Diet Study.

How often facilities are checked

  • China (Art. 109): regulators set the priorities, methods and frequency of supervision from monitoring results, risk assessments and the overall food safety situation, which the law calls risk-graded management (MOFCOM text). The articles I read set no fixed intervals.
  • US (21 U.S.C. 350j): the FDA "shall" identify high-risk facilities, weighing food risk, compliance history and how good the facility's preventive controls are. The statute then sets minimums [24]:
    • high-risk domestic facilities: at least once every 3 years;
    • other domestic facilities: at least once every 5 years;
    • foreign facilities: at least 600 in the first year, then twice the previous year's number for the following five years;
    • the FDA may rely on inspections by state and local agencies.

What operators must do

  • US: every registered facility "shall" carry out a written hazard analysis and put in place risk-based preventive controls, monitoring, corrective actions and verification (350g) [29]. A responsible party must report to the Reportable Food Registry within 24 hours of finding that a food is a "reportable food" (350f) [30].
  • China: businesses may test their own products or use qualified labs (Art. 89). Infant-formula makers must test every batch leaving the factory (Art. 81) (MOFCOM text).

Legal limits samples are tested against

  • China: the national food safety (GB) standards in force, which CFSA lists in its catalogue:
    • pesticide residues: GB 2763-2021 [31];
    • contaminants: GB 2762-2022 [32];
    • mycotoxins: GB 2761-2017 [33];
    • pathogens in prepackaged food: GB 29921-2021 [34];
    • pathogens in bulk ready-to-eat food: GB 31607-2021 [35];
    • veterinary drug residues: GB 31650-2019 [36] and GB 31650.1-2022 [37].
  • US: EPA tolerances, which the FDA enforces [28].

Recalls

  • China (Art. 63): a producer who finds its food fails a standard or may harm health "应当立即停止生产，召回已经上市销售的食品" (shall immediately stop production and recall food already on the market), and must notify businesses and consumers (MOFCOM text).
  • US (350l): the FDA must first give the firm a chance to recall voluntarily. If the firm does not, the FDA may order it to stop distributing, and must offer an informal hearing within 2 days. Only the Commissioner can order a recall, and a press release is required [38].

Imports

  • China:
    • imported food "应当" (shall) meet China's national standards and pass inspection by the entry-exit inspection authorities (Art. 92);
    • importers must audit their foreign exporters (Art. 94);
    • the inspection authorities may assess a foreign country's food safety system and set inspection requirements to match (Art. 101) (MOFCOM text).
  • US:
    • inspection at ports of entry is risk-targeted by food, country and importer history [24];
    • each importer "shall" run a Foreign Supplier Verification Program [39];
    • food that appears adulterated "shall be refused admission" [40];
    • one violative shipment can put a firm under Detention Without Physical Examination (DWPE) through import alerts 99-05, 99-08, 99-14 and 99-15. To get off it, a firm generally needs at least five consecutive clean shipments [41];
    • the countrywide alert 99-15 currently names preserved salted duck eggs from Hong Kong and raisins from Turkey [42].

Published results

  • China: sampling results must be published (Art. 87), and Art. 118 provides for a unified food safety information platform (MOFCOM text).
  • US: the FDA publishes an annual pesticide report. In FY2024 it found 98.2% of domestic and 84.4% of imported human food samples compliant [28].
  • I found no national compliance rates for China from Chinese official sources to set against the US figures.

Approach: I searched China's CFSA risk-monitoring records and its national food safety standards catalogue, the FDCA (2023 US Code edition), FDA import alerts and the FDA FY2024 pesticide residue report. The Food Safety Law itself is not in the datasets, so I took it from the 2025-amended text on the Ministry of Commerce portal; parts of Arts 88, 94, 101 and 118 are summaries rather than verbatim quotes. The CFSA monitoring records I read date from 2012 to 2017, and I did not cover US CDC foodborne-illness surveillance, the FDA Food Code or state programmes, or China customs (GACC) import rules.

Q.03