China Product Recalls — Legal Obligations for Manufacturers

China's Product Quality Law requires manufacturers to recall defective products, with the SAMR overseeing compulsory recalls if companies fail to act voluntarily.

Recall Types

• Voluntary recall � Manufacturer proactively identifies defect and initiates recall. Preferred approach.
• Compulsory recall � SAMR orders recall if manufacturer fails to act. Public notice and penalties apply.

Recall Requirements

Recall plan must include: scope of affected products, notification methods (public announcement + direct notification to known purchasers), remedy (repair, replacement, or refund), and timeline. Reports must be submitted to SAMR at each stage.

Consequences of Non-Compliance

Fines up to 10% of prior year revenue, license suspension or revocation, product seizure, and potential criminal liability for willful violations causing injury or death.