关键词: 食品安全；内部报告奖励；吹哨人；协同监管；社会监督

Abstract: The internal reporting reward mechanism for food safety risks in China is grounded in principle-level legal provisions, but its concrete implementation must rely on lower-level laws with explicit legal elements and effects. To better protect public health, the state has introduced this mechanism into food safety regulation. However, its enforcement leaves wide administrative discretion and may easily encroach upon labor rights and business freedom. Accordingly, the mechanism can only be activated under specific conditions, namely when the reporter is a natural person providing information on potential violations, the information is provided voluntarily, the information is original and substantially contributes to the law enforcement process, and appropriate penalties are imposed. The implementation of internal reporting rewards should balance reporting channels, standardize reward distribution, and incorporate post-event evaluation and adjustment based on practical outcomes to enhance the incentive effect. In the event of disputes over reward decisions, differentiated standards of judicial review should be established—strict scrutiny should be applied to whether the administrative authority has fulfilled its duty to grant a reward, and more deferential scrutiny to the form and amount of reward.

Key words: food safety; internal reporting reward; whistleblower; collaborative regulation; social supervision