Interpretation of the Announcement by the State Administration for Market Regulation on Further Strengthening the Supervision of Consumer Product Recalls in Online Sales
Published 19 June 2025
Sarah Xuan
On June 12, 2025, the State Administration for Market Regulation (SAMR) issued the Announcement on Further Strengthening the Supervision of Consumer Product Recalls in Online Sales (hereinafter referred to as the “Announcement”). The Announcement aims to adapt to the evolving consumption patterns and the development needs of the digital economy, further consolidate the product quality and recall responsibilities of e-commerce operators, and effectively safeguard the legitimate rights and interests of consumers.
This article provides a comprehensive interpretation of this new regulation from the perspectives of its legal basis, regulatory targets, main content, as well as its impact and evaluation.
I. Legal Basis
The Announcement is formulated based on the Law of the People’s Republic of China on the Protection of Consumer Rights and Interests, the E-commerce Law of the People’s Republic of China, the Product Quality Law of the People’s Republic of China, the Regulations for the Implementation of the Law on the Protection of Consumer Rights and Interests, and the Interim Provisions on the Administration of Consumer Product Recalls. These laws and regulations provide clear legal foundations in defining the obligations of e-commerce platforms and operators, the procedures for defective product recalls, information disclosure, and the protection of consumers’ right to know.
II. Regulatory Targets
According to the Announcement, the regulatory targets include:
1. E-commerce platform operators (such as merchants operating stores on JD.com, Taobao, etc.);2. E-commerce operators who sell consumer products through self-built websites or other online services;3. Registered service providers within China entrusted by cross-border e-commerce enterprises, who are regarded as importers or designated agents of overseas manufacturers.
This means that all entities engaged in online sales of consumer products—whether large platforms, small online stores, or parties involved in cross-border e-commerce—are included within the regulatory scope.
III. Main Content
The Announcement systematically regulates online consumer product recalls from five dimensions: information mechanism construction, recall implementation obligations, consumer notification, data support, and cross-border e-commerce supervision. It reflects a closed-loop management approach integrating “prevention + response + supervision.”
(1) Improving the Defective Information Monitoring and Response Mechanism
The Announcement stipulates that when e-commerce operators sell consumer products online (including through live streaming), they must ensure the products meet personal and property safety requirements and establish the following mechanisms:
1. Defect Information Collection Mechanism: Actively gather information from consumer feedback, industry warnings, third-party testing, etc.;2. Verification and Analysis Mechanism: Conduct technical and legal assessments of suspected defect information;3. Handling Mechanism: Formulate response measures and report or initiate the recall process based on the severity of the defect.
This move is intended to shift from “post-incident recall” to “early warning and proactive response,” reinforcing the role of businesses as the primary responsible party.
(2) Precision Push Mechanism for Recall Information
The Announcement requires that recall information be pushed through the National Online Transaction Supervision Platform, utilizing the “Consumer Product Recall Information Sharing” module for regular notifications, specifically:
1. For Platform-Based Sellers: Real-time delivery of defective product information to guide timely removal from shelves;2. For Non-Platform Sellers: Access to recall information via the SAMR official website or recall center to ensure information equality.
This mechanism leverages digital tools to improve the “reach rate” of recalls and serves as a technical support for enhancing transparency in the online sales environment.
(3) Clarifying Obligations to Suspend Sales and Initiate Recalls
The Announcement mandates that platform-based sellers, self-built site operators, and third-party service providers must:
1. Immediately remove defective products from sale upon receiving recall notices;2. Initiate legally required recall procedures, including filing recall plans with authorities, notifying consumers, and offering remedies;3. E-commerce platforms must also cooperate with recall activities and fulfill collaborative responsibilities, such as providing product traceability data and merchant information.
This reflects the principle of “whoever sells is responsible,” promoting the fulfillment of product safety obligations by business operators.
(4) Enhancing Information Disclosure and Safeguarding Consumers’ Right to Know
The Announcement requires that for products undergoing recall, sellers must disclose the following information prominently on the homepage of their e-commerce site:
1. Product name, model, batch number, and risk description;2. Recall scope and remedial measures (e.g., return, exchange, free repair);3. Channels through which consumers can take action and seek remedies.
This provision ensures consumers can promptly access risk-related information and take protective actions, thus improving public participation and recall effectiveness.
(5) Integrating Product Barcode Information to Improve Traceability
For consumer products with barcodes, the Announcement introduces a “barcode-based recall traceability mechanism,” requiring:
1. Producers to include barcode information in recall plans;2. Consumers to query the recall status accurately via the SAMR or recall center websites using barcode + product model + production batch.
This regulation enhances the linkage between recall information and consumption scenarios, laying the groundwork for intelligent recall management.
(6) Defining Obligations of Cross-Border E-commerce Entities
The Announcement clarifies that registered service providers in China, entrusted by cross-border e-commerce enterprises, are regarded as the importers or designated recall implementers for defective products. These entities must fulfill their recall responsibilities in accordance with the law. This measure effectively fills previous regulatory gaps concerning the difficulty of recalling, supervising, and holding cross-border products accountable.
(7) Promoting Co-Governance and Accountability Mechanisms
The Announcement directs regulatory authorities to:
1. Encourage platforms to sign a “Safety and Recall Co-Governance Commitment,” promoting institutionalization of recall mechanisms through industry self-discipline;2. Conduct monitoring and evaluation of the implementation of such commitments.
For failure to fulfill recall obligations, the Announcement prescribes legal penalties, including administrative warnings, deadlines for rectification, fines, and inclusion on a credit blacklist. This section underscores a governance approach combining “routine supervision + accountability,” creating a compliance ecosystem that balances legal enforcement with industry flexibility.
IV. Impact and Evaluatio
The release of the Announcement is a proactive response by the national regulatory system to the safety risks of products sold through emerging online consumption models. It brings multiple positive effects, including:
1. Improved Recall Efficiency and Coverage: Establishes an information-sharing mechanism that facilitates data circulation, enhancing the timeliness and precision of recall actions;2. Reinforced Responsibilities of Platforms and Operators: Promotes a shift from “passive response” to “proactive prevention” among e-commerce entities;3. Enhanced Consumer Awareness and Protection: Improves consumer right to know and participation via public notices and barcode queries;4. Standardization of Cross-Border E-commerce Practices: Implements effective supervision of imported consumer goods, closing regulatory loopholes;5. Modernization of Platform Governance: Explores collaborative governance paths for product safety in the digital age through the synergy of “platform commitment + government supervision.”
That said, the effectiveness of the Announcement depends on the enforcement capacity of regulatory bodies, the technical cooperation of platforms, and the legal awareness of merchants. Continued attention to implementation details and public feedback is essential.
Conclusion
The Announcement by the State Administration for Market Regulation on Further Strengthening the Supervision of Consumer Product Recalls in Online Sales is not only an institutional enhancement but also an upgrade of the consumer rights protection framework in the new era. As online retail becomes a mainstream consumption model, the provisions of the Announcement represent a vital step in modernizing the supervision of product quality and consumer safety in China.