Key Points
- Mandatory labeling: Platforms must add a prominent “No Dine‑In” label for wutangshi 无堂食 merchants to improve consumer/regulatory transparency; draft open for comment through November 16, 2025.
- Platform duties & timing: Platforms must file with authorities within 30 business days, establish dedicated food‑safety units, and ensure staff receive at least 40 hours of training annually (training records kept for two years).
- Monitoring & recordkeeping: Monthly offline sampling must cover ≥ 5% of merchants (with full coverage within two years); retain Internet+ Mingchu Liangzao video ≥ 14 days and order records ≥ six months.
- Enforcement & penalties: Fines include ¥10,000–¥50,000 (≈$1,400–$7,000) for filing failures and up to ¥50,000–¥200,000 (≈$7,000–$28,000) for serious breaches; platforms carry joint liability for third‑party operators.
- Practical impact: The SAMR (市场监管总局) draft will raise compliance costs for platforms and delivery‑only operators but deliver greater traceability and faster regulatory powers (suspensions, data access) over online catering.
No Dine‑In label is at the center of a new SAMR draft that would tighten food‑safety oversight for online catering platforms and delivery‑only merchants.
The State Administration for Market Regulation (Shichang Jianguan Zongju 市场监管总局; SAMR) has published a draft regulation soliciting public comments that would tighten food‑safety oversight of online catering services.
The draft is titled “Supervision and Administration Regulations on the Fulfillment of Food Safety Main‑Responsibility by Third‑Party Online Catering Platforms and Registered Catering Service Providers (Draft for Comment)”.
The draft focuses on clarifying platform responsibilities, strengthening risk controls across the lifecycle of online food service, and improving transparency for consumers.
The public comment period runs through November 16, 2025.
Headline change required: “No Dine‑In” marking — what this means for platforms, merchants and consumers
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Purpose and scope — policy goals and who is covered
Key operational requirements for platforms — compliance checklist
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Requirements for registered catering service providers (merchants)
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Penalties (selected highlights with currency conversions)
Other notable provisions — enforcement, terminology and repeal
Why this matters — quick, practical takeaways for investors, founders, tech teams and marketers
Draft release and comment period
Practical impact for stakeholders — short checklist
How to respond during the comment period — quick tips for stakeholders
Where to read the draft and cite official sources
Final thought
The draft is a material shift in how regulators expect platforms to manage food safety and transparency, especially for delivery‑only merchants, and the No Dine‑In label could become a new default signal for consumer risk assessments.
Full draft (selected articles) — concise English rendering
Below is a concise English rendering of the draft’s core articles.
Headings and numbering follow the draft’s structure but are shortened for readability.
Article 1 — Purpose
To strengthen supervision of food safety in online catering, urge third‑party platforms and registered catering providers to fulfill their food‑safety responsibilities, standardize operations and ensure food safety.
The regulation is formulated under the Food Safety Law and its implementing rules.
Article 2 — Scope
Applies within the PRC to third‑party online catering platform providers (platform providers), their actual operating institutions, third‑party regional operators, and catering service providers that offer services through third‑party platforms or self‑built websites.
Article 3 — Principles
Work will adhere to strict access, risk management, and social co‑governance principles.
Article 4 — Supervision
The State Administration for Market Regulation will guide national supervision work.
County‑level and above local market regulators are responsible for supervision in their administrative areas.
Article 5 — Platform filing
After telecom approval, platform providers must file with the provincial market regulator within 30 business days.
Self‑built website catering providers must file with the county market regulator within 30 business days of telecom filing.
Filing must include domain, IP, telecom license/filing number, company name, address, legal representative or responsible person and contact details.
Articles 6–12 — Platform systems, organization and merchant onboarding
Platforms must establish and publish systems for merchant review, monitoring, stopping illegal behavior, accident handling, complaint handling, and suspension for serious violations.
Platforms must set up dedicated food‑safety units, appoint food‑safety directors and officers, provide training and assessments, and keep records.
Platforms must conduct on‑site verification of merchant qualifications and verify “Internet+ Mingchu Liangzao” linkage.
Merchants without such linkage may not be allowed to transact online.
Platforms must not allow duplicate registration using the same business license.
Articles 13–17 — Monitoring, disclosure, records and data exchange
Platforms must sample inspect at least 5% of merchants offline monthly, achieve full coverage within two years, and retain monitoring records for not less than two years.
Platforms must make merchant qualification information prominent.
Delivery‑only merchants must receive a “No Dine‑In” label.
Platforms must store “Internet+ Mingchu Liangzao” videos for at least 14 days and support regulatory data access via interfaces.
Order records must be retained for at least six months.
Platforms shall verify qualification data against provincial registries and submit variable monthly updates and full quarterly datasets.
Articles 18–27 — Incident handling and delivery management
Platforms must act within two days on county‑level regulator notices (suspension or other measures).
For serious violations, platforms must immediately stop service.
Delivery temperature/time limits, packaging seal rules, and training/assessment obligations for delivery personnel are specified.
Delivery personnel are encouraged to report violations to platforms and local regulators.
Platforms delegating regional services must report third parties to county‑level regulators within 30 business days after signing and report changes within 30 business days of change.
Articles 28–44 — Penalties, jurisdiction and definitions
The draft lists fines and administrative penalties for platform and merchant noncompliance (selected penalties summarized earlier).
Provincial market regulators may impose penalties where violations occur.
Unspecified matters will follow existing food‑safety rules.
The draft defines key terms such as “third‑party platform providers,” “actual operating institutions,” “third‑party institutions,” “delivery‑only providers (wutangshi 无堂食),” and “Internet+ Mingchu Liangzao.”
Article 45 — Implementation
The draft states it will take effect from a date in 2025 to be determined.
The Network Catering Food Safety Supervision and Management Measures will be repealed simultaneously when this regulation enters into force.
Think about how the No Dine‑In label will affect your product, compliance roadmap and go‑to‑market strategy.
