1. There is no clear stipulation in the "Measures for the Administration of Food Circulation Licenses" issued by the State Administration for Industry and Commerce as to whether operators selling edible agricultural products need to apply for a food circulation license. There are different understandings of the law. When some provincial industrial and commercial administration bureaus issued normative documents, they explicitly excluded operators selling edible agricultural products from the need to apply for a food circulation license.

2. Paragraph 2 of Article 29 of the "Food Safety Law" stipulates that only individual farmers who sell their own edible agricultural products do not need to obtain a circulation license. From the perspective of the provisions, two conditions must be met to sell edible agricultural products without obtaining a circulation license. First, there are only individual farmers, and second, the edible agricultural products sold are self-produced. In other words, if only one of the conditions is met, it is not legally required to obtain a circulation license.