Within the legal framework of the food industry, the product self-declaration procedure is structured as a form of “conditional post-market control,” allowing enterprises to proactively place products on the market while bearing full responsibility for safety and regulatory compliance.

In essence, this is not merely an administrative formality but a step that establishes a “minimum compliance threshold” prior to the circulation of goods.

Applicable products include pre-packaged processed foods, food additives, processing aids, as well as materials and utensils that come into direct contact with food, except for certain specific cases where products are not intended for domestic consumption.

The self-declaration dossier generally consists of:

-  a product self-declaration form in the prescribed template; and
- a valid food safety testing certificate (within 12 months), issued by an accredited testing organization.

A key point is that testing content must reflect safety indicators based on risk management principles, aligned with international practices.

In terms of procedure, enterprises publish the declaration via mass media or their own websites, and simultaneously submit the dossier to the designated regulatory authority.

Immediately upon publication, enterprises are entitled to manufacture and trade the product without waiting for prior approval, clearly reflecting the principle of “empowerment coupled with responsibility.”

However, this mechanism also increases legal risks if the dossier is not properly standardized or if the declared information is inaccurate.

An important legal aspect is the obligation to re-declare in the event of material changes such as product name, composition, or origin.

This demonstrates that self-declaration is not a one-time act but an ongoing compliance obligation throughout the product lifecycle, requiring enterprises to maintain robust internal control systems to mitigate post-market enforcement risks.