China's pet-food recall obligation
China's pet-food recall obligation is set by the Pet Feed Administrative Measures (MOA Announcement No. 20, 2018), Article 13, on top of Regulation Article 28 (State Council Decree No. 609).
What the law does not do
Chinese law defines no Class I/II/III recall grading and no fixed-hour recall deadlines, and there is no GB/T 31650-based recall system in the project's sources. This is a key contrast with the US FDA's Class I–III system.
Producer obligations
A producer that finds its product may harm pet health or carries other safety risks must:
- immediately stop production,
- notify sellers and users,
- report to the feed administrative authority,
- proactively recall the product, and
- record the recall and the notifications.
Recalled products must be harmlessly treated or destroyed under the authority's supervision.
Seller obligations
A seller in the same situation must immediately stop sales, notify the producer, supplier and users, report to the authority, and keep records.
Penalties
- A producer that fails to recall (Measures Article 25 → Regulation Article 45): the county-level-or-above feed authority orders the recall and supervises harmless treatment/destruction; in serious cases illegal gains are confiscated with a fine of 1–3× the value of the products to be recalled, and licenses may be revoked.
- If the producer refuses destruction, the authority destroys the products at the producer's cost.
- Sellers that refuse to stop sales are ordered to stop, with fines for non-compliance.
Surveillance and disclosure
MOA and provincial feed authorities conduct regular or ad-hoc product sampling and publish results, including lists of non-compliant producers, sellers and third-party platforms (Measures Article 16).
Honest gap
No verified national recall statistics or outbreak case counts exist in the project's sources — the obligation is procedural, and the published outputs are the sampling/non-compliance lists rather than a graded recall tally.
Sources
CN_recall_system_2023— Pet Feed Administrative Measures (MOA Announcement No. 20, 2018) Art. 13 + Regulation Art. 28: no Class I–III grading, no fixed-hour deadlines; producer/seller obligations; penalty ladder (1–3× value, license revocation, authority-led destruction); MOA sampling/disclosure; honest gap on national recall statistics.