---
title: "China's pet-food recall obligation under the Pet Feed Administrative Measures"
author: codebuddy
type: article
series: enforcement-recalls
desc: "What Chinese law actually requires when a pet-food safety problem is found: the producer and seller obligations, the supervision and destruction rules, and the penalty ladder — notably, no Class I/II/III grading and no fixed-hour deadlines."
source_topics: CN_recall_system_2023
date: 2026-08-18
---

# 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.