食品安全责任约谈制度在我国食品安全监管中发挥重要作用，尤其是在预制菜、食品盲盒等新业态食品安全风险隐患治理方面。但目前我国食品安全责任制度的规范严重滞后于实践需求，其规制体系亟待统一完善。

本文以“我国食品安全责任约谈制度研究”为题，共分为四章，现将主要内容摘要如下：

第一章“我国食品安全责任约谈概述”。我国食品安全责任约谈是指相关监管部门依法对存在食品安全隐患、未及时采取措施消除的食品生产经营者（包括网络平台经营者），或者依法对平台多次出现入网经营者违法经营或者入网经营者的违法经营行为造成严重后果的平台提供者，以通报问题、听取陈述、分析隐患成因、督促整改为内容予以规制的行为。本章梳理我国食品安全责任约谈制度在国家立法层面、地方立法层面的有关规定，结合各地区系统建构食品安全责任约谈规制体系的现状，并通过横向对比发现，该制度仍然存在功能定位不清、实践适用混乱、程序规定不足的问题。

第二章“我国食品安全责任约谈的基础理论”。本章分别从理论依据、性质、基本原则、类型四部分具体构建我国食品安全责任约谈制度的基础理论体系。首先，引入回应性规制理论、精明规制理论以及元规制理论，凸显我国食品安全责任制度的风险预防、社会共治理念。其次，明确我国食品安全责任约谈的风险规制工具属性，提出依法约谈、及时审慎、注重实效和风险预防四大基本原则，为食品安全责任约谈活动提供根本指引。最后，类型化处理食品安全责任约谈制度，对非法定食品安全责任约谈视情况降低程序要式要求，并排除信用规制适用，以平衡我国食品安全责任约谈适用的实效性与合法性。

第三章“我国食品安全责任约谈的适用范围与条件”。纵览各地有关食品安全责任约谈制度的规范实践，均未体现平台经营者自我规制与政府规制的互动，其适用范围与条件有待完善。因此，我国食品安全责任约谈的适用设定应当采用分类规制模式，即在面向所有食品生产经营者（包括网络平台经营者）实施风险预警型责任约谈基础上，单独强调平台经营者的自我规制义务。其中，针对前者的适用范围可具体为：一是存在涉嫌违法违规行为，未及时采取措施消除的；二是存在造成一定危害后果但法律法规尚未规定为违法的行为，未及时采取措施消除的；三是发生食品安全问题，可能引发食品安全风险蔓延的；针对后者，其适用范围与条件重点在于厘定平台责任界限。

第四章“我国食品安全责任约谈的程序规制”。目前，我国食品安全责任约谈仍存在被约谈方程序性权利保障不足、启动时点过早、公众参与缺位等程序规范问题。为此，本章明确被约谈方知情权、陈述申辩权以及（申请）回避权等程序性权利，并通过梳理、对比各地实践，结合食品安全监管特色分别制定事前、事中、事后三阶段各流程步骤的具体工作方案，以期提高食品安全责任约谈制度应用的可操作性。

The system of responsibility interview in the field of food safety plays an important role in the government supervision of China, especially in the management of food safety risks and hidden dangers of new business forms such as prefabricated dishes and food blind boxes. However, the current liability system of food safety in China seriously lags behind the practical needs, and its regulatory system urgently needs to be unified and improved.

This paper is divided into four chapters under the title of "Research on The System of Responsibility Interview in The Field of Food Safety in China", and the main contents are summarized as follows:

Chapter I "Overview of The Food Safety Responsibility Interview in China". The food safety responsibility interview in China refers to the behavior of regulating food producers and operators (including online platform operators) who have food safety hidden dangers and fail to take timely measures to eliminate them, or platform providers whose illegal operations have occurred on the platform for many times or caused serious consequences by the illegal operations of the network operators. This chapter sorts out the relevant provisions of China's food safety responsibility interview system at the national and local legislative levels, combines the current situation of the system construction of food safety responsibility interview regulation system in various regions, and finds through horizontal comparison that the system still has problems such as unclear functional positioning, confusion in practice application and insufficient procedural provisions.

Chapter II "Basic Theory of Food Safety Responsibility Interview in China". This chapter constructs the basic theoretical system of food safety responsibility interview system from four parts: theoretical basis, nature, basic principles and types. Firstly, the theory of responsive regulation, shrewd regulation and meta-regulation is introduced to highlight the concept of risk prevention and social governance of food safety responsibility system in China. Secondly, the attribute of risk regulation tool of food safety responsibility interview is clarified, and four basic principles are put forward: legal interview, timely and prudent, pay attention to effectiveness and risk prevention, which provides fundamental guidance for food safety responsibility interview activities. Finally, the food safety responsibility interview system is treated by types, and the requirements of procedures are reduced for non-legal food safety responsibility interview according to the situation, and the application of credit regulation is excluded, so as to balance the effectiveness and legality of the application of food safety responsibility interview in our country.

Chapter III "The Applicable Scope and Conditions of Food Safety Responsibility Interview in China". Throughout the normative practice of food safety responsibility interview system in various places, it does not reflect the interaction between self-regulation of platform operators and government regulation, and its applicable scope and conditions need to be improved. Therefore, the applicable setting of food safety responsibility interview in China should adopt a classified regulation mode, that is, on the basis of implementing risk early warning type responsibility interview for all food producers and operators (including online platform operators), separately emphasize the self-regulation obligations of platform operators. Among them, the applicable scope for the former can be specifically: first, there are suspected illegal acts, and no timely measures have been taken to eliminate them; second, there are acts that cause certain harmful consequences but have not been stipulated as illegal by laws and regulations, and no timely measures have been taken to eliminate them; third, there are food safety problems, which may lead to the spread of food safety risks; for the latter, the scope and conditions of application focus on determining the boundaries of platform responsibility.

Chapter IV "Procedural Regulation of Food Safety Responsibility Interview in China". At present, there are still some procedural problems in food safety responsibility interview in China, such as insufficient procedural rights protection of the interviewee, premature start time, and lack of public participation. Therefore, this chapter clarifies the procedural rights of the interviewee, such as the right to know, the right to explain and the right to avoid (apply). Through combing and comparing the practices of different places, and combining with the characteristics of food safety supervision, specific work plans for the three stages of pre-event, in-event and post-event are formulated respectively, in order to improve the operability of the application of food safety responsibility interview system.