Current-law scope and cautions
- China does not recognize a general “three-tier commission safe harbor.” Pyramid-selling characterization focuses on recruitment, entry/qualification fees and remuneration based on downline headcount or sales performance.
- Lawful direct selling is separately licensed and regulated and generally uses direct sellers selling to final consumers rather than multi-level recruitment remuneration.
- Commercial structure and actual compensation flows matter more than marketing labels.
Use: This is a screening/estimation tool, not a legal opinion. Confirm the latest primary authority, regulator practice, local rules and transaction documents before acting.
