A recent China–Australia collaborative review examined similarities and differences in the food safety risk assessment systems of China, Australia and New Zealand, Canada, and the U.S., with the aim of identifying areas that could support improvements to the Chinese system.

Key differences identified between the national food safety risk assessment systems were the level of cohesiveness among stakeholders and the level to which each country promotes the international harmonization of standards. The evidence highlights a need for greater capacity-building in risk assessment in China that may support stakeholder cohesion, improve hazard identification, and allow regulators to more readily keep abreast of changes to international standards.

Australia and New Zealand

The Australia and New Zealand food regulatory system consists of three major elements including the development of food policy, the establishment of food standards, and overseeing the implementation of these food standards and policy. This system is multifaceted and involves various sectors which include the Australian and New Zealand governments, supplemented by governmental enforcement agencies from the states and territories of Australia and local municipal councils. The Food Minister's Meeting (previously the Australian and New Zealand Ministerial Forum on Food Regulation) is responsible for policy development and is supported by the Food Regulation Standing Committee.

In Australia, the administration of food safety is a cooperative task that is shared by both central and state governments. Ensuring the safety of imported foods falls under the jurisdiction of the Department of Agriculture, Water and the Environment (DAWE), who oversees inspection of imported and exported food. In New Zealand, it is the Ministry for Primary Industries that governs the inspection of imported and exported food.

The U.S.

The U.S. Food and Drug Administration (FDA) employs a risk-based strategy for food safety management, consisting of nine steps:

  1. Plan strategically, consult with various stakeholders to identify the food safety objective
  2. Rank the risk associated with public health
  3. Gather specific information related to the risk studied
  4. Evaluate and score the risks with regards to impact on public health
  5. Consult with other major stakeholders in food safety
  6. Evaluate factors including consumer concerns, market impact, and detrimental environment impacts
  7. Prioritize manpower to manage risks
  8. Continuously assess the efficiency of the risk management system
  9. Conduct all duties in a coordinated and unbiased manner involving all relevant stakeholders.

The U.S. food safety system comprises the federal regulatory system and the state regulatory program. As for federal entities, the major agencies are the Food and Drug Administration (FDA), the U.S. Department of Agriculture’s Food Safety and Inspection Service (USDA’s FSIS), the Environmental Protection Agency (EPA), and the National Marine Fisheries Service (NMFS). FDA has jurisdictional authority over local and imported foods, excluding meat and poultry. The Center for Food Safety and Applied Nutrition (CFSAN) within FDA oversees the safety, nutritional values, sanitary conditions, and labeling of products within the food sector. EPA is responsible for the licensing of all pesticide products, and NMFS conducts the assessment and grading of seafood. There are more than 3,000 state and local agencies assisting FDA in regulating food safety for the hospitality, food service, and retail sectors.


In Canada, the food safety regulatory bodies are Health Canada (HC) and the Canadian Food Inspection Agency (CFIA). HC has jurisdiction over the health protection rule on a federal basis and regulates the food safety measures of the Food and Drugs Acts. The agency relies on various acts that were developed to address food safety risks associated with health of the public. CFIA is the enforcement body that ensures compliance with the acts. Other supporting agencies include the Agriculture and Agrifood Canada, and the Public Health Agency of Canada.


The food regulatory system of China consists of a three-layered system based on basic, subordinate, and enforcement laws. The basic laws are responsible for the quality and safety of agricultural food, which falls under the jurisdiction of the Ministry of Agriculture. The agency’s function is to ensure compliance with fresh produce cultivation, farming practices, fresh produce processing, food packaging in hygienic conditions, and all other safe food practices in a processing plant.

Basic laws have the highest hierarchy status compared with all other laws, followed by subordinate laws, which have jurisdiction over food businesses, ensuring the labeling of foods conform to regulatory guidelines, and addressing additives in food. The subordinate laws differ in function compared to the basic laws but complement the basic laws by issuing guidelines that ensure processed foods are safe for human consumption.

The whole food safety system functions with the aid of the relevant provincial government in setting control specifications. The government of China established the Food Safety Law (FSL) in 2009, which was developed from the preexisting Agrifood Quality and Safety Law implemented in 2006, and before that, the Agriculture Law in 2003. The FSL ensures that China’s food safety system upholds the safety and quality of food. The FSL also manages food safety incidents by providing rectifying recommendations.


Regarding maximum residue limits (MRLs) for pesticides, China has established extensive limits that industry must adhere to for fresh food, primarily in vegetables, fruits, eggs and meat; however, limited coverage remains for processed food. In contrast, pesticide residue MRLs are well established both in fresh and processed food in Australia, New Zealand, the U.S., and Canada. Canada employs a more sophisticated Ranked Risk Assessment system, and the U.S. employs the advanced iRISK computer software to assist in pesticide residue assessment. For microbiological risk assessment, China, Australia, New Zealand, the U.S., and Canada use the Quantitative Microbiological Risk-Assessment system.

As for government investment in food safety, China applied for a loan from the World Bank of $400 million in 2021 for funding to improve food safety. The loan was approved, thereby providing resources to further improve food safety. Other countries have also invested varying amounts of money in raising their food safety standards. The Australian government invested $1.3 billion Australian dollars in 2021 to improve modern manufacturing. An $86 million food safety program was announced by the New Zealand government in 2014. The Canadian government invested $162.6 million in food safety in 2021. In the U.S., the USDA announced in 2021 that it would invest more than $4 billion to improve food safety.

When it comes to food fraud, global statistics indicate that China has a higher incidence compared to other countries. The Canadian government invested $3.1 million to enable CIFA to hire more staff members to handle food fraud cases in 2019–2020. To reduce the prevalence of food fraud, the Food Safety Modernization Act (FSMA) is effective in the U.S.

As part of the efforts to improve food safety, China has implemented Hazards Analysis and Critical control Points (HACCP) in the manufacturing sector, which is consistent with the practices used by Australia, New Zealand, Canada, and the U.S.

With regard to food handlers' food safety knowledge, China is expanding its education policy on food handlers with the focus on how poor food handling can lead to poor consequences for public health. In Australia, New Zealand, Canada, and the U.S., food handlers are very often required to possess an accredited qualification for food handling. This can be used as a guide to develop food handlers' food safety knowledge in China.