What changes the answer
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Signal
Ask the operating question
Why it changes the route
Product category
What are the current facts, parties, dates and documents for product category?
Product category and technical facts determine the applicable customs, recall or regulatory regime.
Nature/severity of defect
What are the current facts, parties, dates and documents for nature/severity of defect?
Severity, incident history and distribution determine recall duties and urgency.
Manufacturer/importer/seller role
What are the current facts, parties, dates and documents for manufacturer/importer/seller role?
Manufacturer/importer/seller role can change the applicable legal route, evidence requirement, timing or responsible entity.
Distribution scale
What are the current facts, parties, dates and documents for distribution scale?
Distribution scale can change the applicable legal route, evidence requirement, timing or responsible entity.
Sector regulator and incident history
What are the current facts, parties, dates and documents for sector regulator and incident history?
Sector regulator and incident history can change the applicable legal route, evidence requirement, timing or responsible entity.
Prepare before you escalate
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
01Product/SKU/lot recordsEstablish the relevant parties, dates, amounts and regulatory facts shown by product/sku/lot records.
02Complaints/incident evidenceEstablish notice of defects, incident frequency and the response already taken.
03Test reportsEstablish the nature, scope and severity of the suspected defect.
04Distribution/customer listIdentify affected products, locations, customers and recall reach.
05Existing regulator communications and proposed corrective actionShow prior directions, stated concerns and response deadlines.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.
Sources last checked:
Product Quality Law / Civil Code product liabilityNational People’s Congress
SAMR product recall ruleswww.samr.gov.cn
E-Commerce Law where platform liability is relevantNational People’s Congress
