Amending China’s Notion of a “Consumer”: Lessons from Comparative Analysis of the PRC Consumer Protection Law

Kristie Thomas*

*Corresponding author for this work

Research output: Contribution to journalArticlepeer-review


Who does the law treat as a “consumer” and why does it matter? How should China’s notion of a “consumer” best be articulated within the law and applied in practice? This article will attempt to answer these intriguing questions by first focusing on the approach taken to define a “consumer” in China’s Law on the Protection of Consumer Rights and Interests before examining the legal notion of a “consumer” in comparative perspective, in order to further understand the competing rationales behind the consumer protection law. This article will explore this Chinese definition of a “consumer” to propose how China’s vague and unworkable statutory definition of a ‘consumer’ should be amended in future.
Original languageEnglish
Pages (from-to)435-456
JournalJournal of Consumer Policy
Issue number3
Early online date11 May 2022
Publication statusPublished - Sept 2022

Bibliographical note

© 2022, The Author(s). This article is licensed under a Creative Commons Attribution 4.0 International License, which permits use, sharing, adaptation, distribution and reproduction in any medium or format, as long as you give appropriate credit to the original author(s) and the source, provide a link to the Creative Commons licence, and indicate if changes were made. The images or other third party material in this article are included in the article's Creative Commons licence, unless indicated otherwise in a credit line to the material. If material is not included in the article's Creative Commons licence and your intended use is not permitted by statutory regulation or exceeds the permitted use, you will need to obtain permission directly from the copyright holder. To view a copy of this licence, visit


  • China
  • Comparative law
  • Consumer definition
  • Consumer protection


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