4 questions before you choose the route.
This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.
Does this issue require separate analysis?
Related-party check.
OwnerWhat is the extra margin for?
Market vs slush.
MarginWho are their customers?
Official/hospital overlay.
CustomersCan you audit and terminate?
Contract.
ControlWorking rule: Using distributors is normal. Risk concentrates when the distributor is a former employee’s company, when extra ‘marketing support’ is off-books, when they cover hospitals or government buyers, or when they sell outside authorised scope.
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Does a distributor make us safe from AUCL?
No. Using a third party is a listed pattern, not a shield.
Where is the contracts distribution page?
Use the linked specialist resource when Compliance Risks When Using Distributors in China turns on detailed evidence, procedure or risk assessment.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.