China Legal Guides · Consumer response

China 12315 and SAMR Consumer Dispute Response SOP

Consumer mediation and a regulatory report are different legal processes. A withdrawal may end mediation but does not bind the authority. Control staff communications, verify the inspection record and preserve the parallel civil defence from hour zero.

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Operational orientation · Qualified PRC counsel required for fact-specific decisions

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Response switch

Preparing before a complaint? Review the inspection-note controls and response checklist.

Command principle

Treat mediation, regulatory investigation and civil exposure as separate but connected tracks.

Use one legal contact, preserve transaction and inspection evidence, correct factual errors before signing, and maintain consistent positions across the consumer, authority and civil channels. Paying or settling one channel does not automatically close another.

Complaint response board

Control the first 72 hours.

The sequence is an operational orientation. Deadlines and procedural rights depend on the actual notice and authority.

Time on site

Identify whether the matter is mediation, a regulatory report, an on-site inspection or more than one track. Preserve communications and stop staff from offering unverified explanations.

Inspection record control

Do not sign a narrative containing facts you have not verified. Annotate disagreements, correct errors, strike blank lines where appropriate, retain a copy and avoid a blind refusal to sign.

Control the response

Three owners. One factual record.

Clear ownership reduces inconsistent statements and lost evidence.

Separate mediation, investigation and civil tracks; preserve procedural rights and keep written positions consistent.

Civil defence structure

Build the response in four layers.

The existing guide separates the civil defence so disputed issues do not obscure basic transaction facts.

Undisputed facts

Confirm date, product, price, delivery and other facts supported by the record.

Fact track

Disputed facts

Identify inaccurate statements, buyer modification and contested inspection narratives.

Evidence track

Legal characterisation

Separate defect, misleading statement, fraud, consumer status and remedy questions.

Law track

Alternative remedies

Assess repair, replacement or refund options without conceding disputed liability.

Remedy track

Before the next complaint

Prepare the consumer-response system.

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Escalation tree

Post a clear escalation route for stores, customer service and platform teams.

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Counsel roster

Maintain current legal and external-counsel contacts for urgent reports and inspections.

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Inspection-note checklist

Give responsible staff a short factual verification and annotation checklist.

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Approved scripts

Prepare accurate holding language that does not promise closure or admit unverified facts.

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Evidence map

Know where product, listing, chat, transaction and warehouse records are retained.

Frequently asked question

A common inspection-record decision.

The right step depends on the record and the authority’s procedure.

Should the company refuse to sign inspection notes?

Do not refuse blindly. Verify the facts, annotate disagreements and correct inaccurate statements before signing. Retain a copy and obtain PRC counsel advice where the record may affect a material penalty, licence or civil claim.

Does a consumer withdrawal close the regulatory matter?

Not necessarily. Withdrawal may end a voluntary mediation process, but it does not bind SAMR or another authority conducting a public-law investigation.

Source station

Check the current authority materials and the broader consumer-protection guide before acting.

State Administration for Market Regulation China Consumer Protection guide Food safety punitive damages Editorial policy

Response library

Open the route that owns the next issue.

These existing pages provide the broader legal or issue-specific context.

01 · Flagship route

China Consumer Protection Law Guide

Use for the wider consumer-protection framework and connected risk areas.

Open specialist route →02 · Food route

Imported Food Punitive Damages

Use when a food-safety allegation creates statutory-damages exposure.

Open specialist route →03 · Market route

CBEC vs General Trade

Use when import channel, labelling and consumer-liability allocation matter.

Open specialist route →

Legal escalation

Escalate when the response becomes fact-specific.

Use qualified PRC counsel when the record, proposed penalty, licence, product allegation or parallel litigation creates material exposure.

An inspection record is disputedThe authority’s draft attributes an admission, defect or fraud statement the company contests.

A material penalty is proposedA hearing, defence submission or licence consequence may be in play.

Civil proceedings are activeStatements in mediation or inspection may be used in a later claim.

Browse Product Liability counselCompare relevant China counsel profiles.

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Prepare a structured enquirySummarise the route, timeline, record and desired outcome.

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Educational information only — not legal advice. Procedures, laws and enforcement practice can change; no lawyer-client relationship is created through use of this page.