Yifan Tang is a product liability and regulatory compliance attorney at Jinchang Hexie Law Firm, with 11 years of experience advising manufacturers and importers on product recall procedures and obligations under Chinese law. His practice serves both domestic enterprises and foreign-invested companies producing goods for the Chinese market.

Mr. Tang graduated from Renmin University of China Law School and has completed specialized training in China's product recall regulatory framework at the China National Institute of Standardization. He regularly advises clients on recall planning, regulatory reporting, and consumer notification strategies.

⚖️ Product Recall Practice

• ⚖️ Mandatory recall compliance — reporting obligations under Product Quality Law
• 🛡️ Voluntary recall planning — recall plans, consumer notification, corrective actions
• 📜 Regulatory investigations — SAMR inquiries, inspection responses
• 💼 Cross-border recall coordination — aligning Chinese recall requirements with global programs

Product Recall Law in China

China's product recall system is governed primarily by the Product Quality Law, the Consumer Rights Protection Law, and product-specific recall regulations administered by the State Administration for Market Regulation (SAMR). The Regulations on the Recall of Defective Automobile Products (effective 2013) and the Measures for the Administration of Recall of Food and Cosmetics are among the most developed sectoral recall frameworks.

Under Article 33 of the Consumer Rights Protection Law, a manufacturer that discovers its product has a defect that may cause harm to consumers must immediately report to SAMR and initiate a recall. Failure to do so can result in administrative penalties, including fines of up to RMB 500,000, public notification of the violation, and potential civil liability for any harm caused by the defect.

Article 46 of the Product Quality Law establishes strict liability for defective products: the manufacturer bears liability regardless of fault. Once a product is proven defective, the manufacturer is liable for resulting damages. This places a heavy burden on manufacturers to monitor product safety proactively.

Recall Procedures

Product recall procedures in China follow a structured framework. Upon discovering a defect, the manufacturer must submit a defect investigation report to SAMR within seven days, followed by a recall plan within 15 days. The recall plan must specify the scope of the recall, the corrective action, and the method of notifying consumers.

Communication with consumers must be conducted through publicly accessible channels, typically including newspaper announcements, website postings, and direct notification where contact information is available. Under the Regulations on the Recall of Defective Automobile Products, manufacturers must establish a complaint database and report consumer complaints to SAMR quarterly.

Mr. Tang advises foreign manufacturers to establish a China-specific recall protocol that addresses the unique requirements of Chinese regulators. Key elements include appointing a China-based recall coordinator, maintaining a Chinese-language consumer complaint system, and pre-positioning legal counsel familiar with SAMR procedures. Proactive compliance significantly reduces the risk of escalated penalties and reputational harm.

Practice Focus for Yifan Tang

Yifan Tang advises foreign individuals and companies on China-related legal matters with an emphasis on clear process, bilingual documentation, and enforceable outcomes. The following sections expand the professional methodology used across active mandates.

Professional Approach

I build every engagement around a clear scope, a written strategy, and measurable milestones. Clients receive plain-language risk maps, document checklists, and decision trees before major steps are taken. I coordinate with translators, notaries, and local counsel when cross-border evidence or bilingual filings are required, and I keep privilege and confidentiality controls explicit from day one.

Communication is scheduled and documented. Status notes summarize what changed, what remains open, and what decision is needed from the client. I prefer early settlement pathways when they protect value, and I prepare litigation or arbitration files as if trial were inevitable so negotiation leverage stays real.

Working With Foreign Clients

Foreign individuals and companies often face unfamiliar filing windows, authority practices, and cultural expectations in Chinese proceedings. I translate those constraints into practical timelines, identify which facts must be proven with original seals versus certified copies, and design bilingual work products that remain usable in both home-country and PRC forums.

Where board approvals, power of attorney chains, or apostille/legalization steps are required, I sequence them so substantive work is not stalled. I also flag immigration, employment, and regulatory knock-on effects so a contract win does not create a compliance loss elsewhere.

Quality and Ethics

I do not promise outcomes. I promise disciplined process, candid risk assessment, and advocacy within the bounds of PRC law and professional rules. Fee arrangements, conflict checks, and engagement letters are handled before substantive advice begins. Sensitive personal data and commercial secrets are segregated with access limited to the matter team.

After closing a matter I deliver a short handover pack: final agreements, authority receipts, open obligations, and renewal or enforcement calendars. That discipline reduces repeat disputes and keeps institutional knowledge with the client.

Professional Approach

I build every engagement around a clear scope, a written strategy, and measurable milestones. Clients receive plain-language risk maps, document checklists, and decision trees before major steps are taken. I coordinate with translators, notaries, and local counsel when cross-border evidence or bilingual filings are required, and I keep privilege and confidentiality controls explicit from day one.

Communication is scheduled and documented. Status notes summarize what changed, what remains open, and what decision is needed from the client. I prefer early settlement pathways when they protect value, and I prepare litigation or arbitration files as if trial were inevitable so negotiation leverage stays real.