China Pricing Law and Promotion Compliance for E-Commerce

China's pricing regime for e-commerce rests on the Price Law of the PRC (effective May 1, 1998) and the Provisions on Clearly Marking Prices and Prohibiting Price Fraud (effective July 1, 2022), which set a 7-day comparison-price cap and penalties of up to 5x illegal gains. For foreign sellers, china pricing law promotion compliance is not a marketing detail — it is a core operating requirement enforced by the State Administration for Market Regulation (SAMR). This guide explains the display rules, promotion rules, fraud definitions and penalty ranges you will typically need to build into your storefront before launch.

Quick Facts

What Is the Legal Basis for China's Pricing Rules?

You will operate under two core instruments: the Price Law of the PRC and the Provisions on Clearly Marking Prices and Prohibiting Price Fraud (SAMR Decree No. 56). The Price Law took effect on May 1, 1998, having been passed on December 29, 1997, and establishes operators' pricing autonomy alongside mandatory clearly-marked-price and anti-fraud duties (National Laws and Regulations Database — Price Law of the PRC).

The 2022 Provisions consolidated and replaced two older rules — the 2000 Order No. 8 Provisions on Clearly Marking Prices and the 2001 Order No. 15 Provisions on Prohibiting Price Fraud — which were repealed simultaneously when the new rules took effect (SAMR — Provisions on Clearly Marking Prices and Prohibiting Price Fraud). In practice, this means any pre-2022 compliance templates you find are obsolete.

The Provisions contain 27 articles covering marking obligations, price comparison, discounts, gifts, eight categories of price fraud, three network-transaction rules and three exemptions (SAMR — Key Points Interpretation). Penalties are imposed under the Price Law, the Anti-Unfair Competition Law, the E-Commerce Law and the Provisions on Administrative Penalties for Price Violations (third revision effective December 4, 2010) (National Administrative Regulations Database — Provisions on Administrative Penalties for Price Violations).

What Must a Product Listing Display?

Every product you list must show the product name, the price and the pricing unit — these are the three mandatory elements for goods (SAMR — Provisions on Clearly Marking Prices). For services, you must display the service item, the service content, and either the price or the pricing method. You may not charge anything beyond the marked price or add any unmarked fees at checkout.

For online sales specifically, Article 13 of the Provisions requires that prices be clearly marked on the web page in text or image form (Ministry of Justice — Provisions on Clearly Marking Prices). Prices must be shown as RMB amounts in Arabic numerals, with other information in standard Chinese characters (Article 9). Ancillary services such as delivery, carrying, installation or debugging must also be clearly priced, and if a third party provides them, that must be prominently distinguished (Article 11).

How Do Comparison Prices and "Original Prices" Work?

China does not require you to display a historical "original price." Instead, the rules govern the "comparison price" — the reference price you show next to your promotional price. Where you do not mark the details of the comparison, it may not be higher than the lowest transaction price of the same product in the same venue within the previous 7 days; if there were no transactions in those 7 days, it may not be higher than the last transaction price before the comparison (SAMR — Provisions, Article 16).

If you use a manufacturer's suggested retail price (MSRP) as the comparison, you must clearly label it as such, and update it immediately whenever the MSRP changes (Ministry of Justice — Provisions). You also may not use a price that has no basis or cannot be compared as a discount or comparison benchmark (Article 17). Our advisory team recommends building a documented price-history log per SKU so any comparison price you display is traceable to actual transactions.

What Promotion Tactics Are Prohibited?

The central prohibition is "raise-then-cut": without reasonable grounds, you may not temporarily and significantly raise the marked price shortly before a discount and use that inflated figure as the discount baseline (SAMR — Provisions, Article 17). Note the scope: normal price fluctuations are not illegal — the rule targets artificial pre-promotion spikes used as fake baselines.

Gift promotions carry their own duties. You must display the gift's name and quantity; if the gift is priced, the marked price must reflect its current selling price in the same venue (Ministry of Justice — Provisions). Article 19 lists eight categories of price fraud, including fake discounts or fake price comparisons (item 3), refusing without justification to honor a price commitment (item 5), downplaying unfavorable price conditions to induce transactions (item 6), and refusing to redeem points or vouchers (item 7).

For network transactions, Article 20 adds three rules: the price shown on a listing's first page or prominent position may not be lower than the price on the detail page (preventing low-price baiting with higher checkout prices); announced promotion scope must match actual scope; and platforms may not use technical means to force merchants into false or misleading price displays (SAMR — Provisions, Article 20).

What Are the Penalties If You Get It Wrong?

Penalty exposure scales with the violation type. For price fraud, regulators confiscate illegal gains and may impose a fine of up to 5 times the illegal gains; where there are no illegal gains, the fine ranges from RMB 50,000 to RMB 500,000, and serious cases can bring suspension of business or license revocation (National Administrative Regulations Database — Provisions on Administrative Penalties for Price Violations). Violations of clearly-marking-price duties carry confiscation of illegal gains plus a fine of up to RMB 5,000.

More serious conduct — price collusion, selling below cost to squeeze rivals, or price discrimination — attracts confiscation plus up to 5 times illegal gains, or RMB 100,000 to RMB 1,000,000 where there are no illegal gains, again with suspension or revocation possible in serious cases (National Administrative Regulations Database — Provisions on Administrative Penalties for Price Violations). Venue and platform providers that fail to cooperate or force promotional conduct face fines up to RMB 30,000, rising to RMB 30,000–100,000 in serious cases (Articles 24–25 of the Provisions).

Two mitigating points matter in practice. First, Article 21 exempts three situations from price-fraud classification: no subjective intent to deceive, the consumer actually obtained a larger discount, or rounding off small change consistent with trade custom — these are expressly "not price fraud" (SAMR — Provisions, Article 21). Second, Article 26 provides lighter or reduced penalties for operators who proactively eliminate or mitigate harm and promptly refund overcharges (Ministry of Justice — Provisions). Actual fine amounts sit within these statutory ranges and are set by the enforcement authority's discretion, not fixed.

How Should a Foreign Seller Build a Compliance Workflow?

You will typically need a repeatable internal process rather than ad-hoc checks. Our advisory team recommends the following six-step framework, which maps directly to the statutory duties described above:

1. Map every displayed price element. For each SKU and service, confirm name, price and pricing unit (or service item, content and pricing method) are visible on the page, in RMB with Arabic numerals.
2. Log transaction history per SKU. Maintain a dated record of actual transaction prices per sales venue so any 7-day lowest-price calculation is auditable.
3. Validate every comparison price. Before publishing a crossed-out or "was" price, verify it does not exceed the 7-day lowest transaction price (or last transaction price), or is clearly labeled as MSRP and kept current.
4. Screen promotion mechanics. Check that no discount baseline was artificially raised pre-promotion, gift names/quantities are displayed, and announced promotion scope matches the actual scope.
5. Reconcile homepage and detail-page prices. Ensure the listing page price is never lower than the checkout/detail price, and that vouchers, points and commitments are honored as displayed.
6. Document intent and remediation. Keep records showing no deceptive intent, and prepare a refund protocol so any overcharge is promptly returned — which also supports lighter penalties under Article 26.

What to Watch Out For

Comparison-price direction errors. The homepage rule runs one way: the first-page or prominent-position price may not be lower than the detail-page price. Teams familiar with Western "strikethrough" conventions sometimes reverse this; verify against Article 20(1) (SAMR — Provisions).

"Original price" misconceptions. The law speaks of "comparison prices," not a mandatory historical original price. Do not build templates that claim you must display a historical price — the binding constraint is the 7-day lowest transaction price cap (SAMR — Provisions, Article 16).

Overbroad reading of the raise-then-cut ban. Article 17 prohibits temporary, significant pre-promotion increases used as baselines without reasonable grounds. Ordinary price movements are lawful; only artificial baseline inflation is targeted (SAMR — Provisions, Article 17).

Multi-law overlap. Violations of the price-comparison, discount and network rules are penalized under four instruments — the Price Law, the Anti-Unfair Competition Law, the E-Commerce Law and the Provisions on Administrative Penalties for Price Violations (Article 23) — so exposure may arise under more than one regime simultaneously (SAMR — Provisions, Article 23).

Costs are qualitative, not standardized. There is no official standard for pricing-system or promotion-configuration costs; treat any such figures you encounter as estimates and budget qualitatively with your own vendors.

Frequently Asked Questions

Q: When did China's current pricing display rules take effect?

A: The Provisions on Clearly Marking Prices and Prohibiting Price Fraud (SAMR Decree No. 56) took effect on July 1, 2022, having been issued on June 2, 2022. They repealed the 2000 and 2001 predecessor rules on the same date, so any compliance template older than 2022 should be rebuilt against the current 27-article text.

Q: What three elements must a goods listing display?

A: For goods, you must clearly display the product name, the price and the pricing unit. For services, the required elements are the service item, the service content, and the price or pricing method. Charging beyond the marked price or adding unmarked fees is prohibited in both cases.

Q: How is a comparison price capped if I do not mark its details?

A: Where comparison details are not marked, the comparison price may not exceed the lowest transaction price of the same product in the same venue within the previous 7 days. If there were no transactions in that window, it may not exceed the last transaction price before the comparison was made.

Q: Is raising prices before a promotion always illegal?

A: No. Article 17 prohibits temporarily and significantly raising the marked price without reasonable grounds and using it as a discount baseline. Ordinary price fluctuations remain lawful; only artificial pre-promotion spikes designed to fake a discount baseline fall within the prohibition.

Q: What are the fines for price fraud?

A: Regulators confiscate illegal gains and may fine up to 5 times that amount. Where there are no illegal gains, the fine ranges from RMB 50,000 to RMB 500,000. Serious cases can result in suspension of business for rectification or revocation of the business license, with amounts set at the enforcement authority's discretion.

Q: Are any discount errors exempt from price-fraud classification?

A: Yes — three categories under Article 21 are expressly not price fraud: absence of subjective intent to deceive, situations where the consumer obtained a larger discount than promised, and rounding off small change consistent with trade custom. Cite the exemption alongside the category when assessing exposure.

Q: Can my listing page show a lower price than checkout?

A: No. Article 20(1) provides that the price on a listing's first page or prominent position may not be lower than the price on the detail page. This targets low-price baiting where consumers are drawn in by a headline price and charged more at settlement.

Q: What rules apply to gifts in promotions?

A: You must display the gift's name and quantity. If the gift is priced, the marked price must reflect its current selling price in the same sales venue. Refusing to redeem points or vouchers that were offered is separately listed as price fraud under Article 19(7).

Q: What happens if a platform forces misleading price displays?

A: Article 20(2) prohibits trading platforms from using technical means to force merchants on the platform into false or misleading price marking. Venue providers that fail to cooperate with enforcement or force promotional conduct face fines up to RMB 30,000, or RMB 30,000–100,000 in serious cases.

Q: How can I reduce penalties if a violation occurs?

A: Article 26 allows lighter or reduced penalties for operators who proactively eliminate or mitigate harmful consequences and promptly refund overcharged amounts. Building a refund protocol and documented remediation steps before a promotion therefore directly reduces your exposure. CnBusinessHub can help you evaluate your options and coordinate with qualified local counsel.

Conclusion

Three takeaways for your China e-commerce pricing program:

1. Anchor to the 2022 Provisions. SAMR Decree No. 56, effective July 1, 2022, replaced the 2000 and 2001 rules; all display, comparison and promotion templates should be rebuilt against its 27 articles.
2. Treat comparison prices as evidence-backed claims. The 7-day lowest-transaction-price cap and the MSRP labeling duty mean every reference price you display should be traceable to recorded transactions.
3. Budget for penalty ranges, not point estimates. Price fraud carries up to 5x illegal gains or RMB 50,000–500,000 where there are none, while marking violations cap at RMB 5,000 — and prompt refunds under Article 26 can mitigate outcomes.

For personalized guidance on your China e-commerce licensing pathway, contact the CnBusinessHub advisory team at consult@CnBusinessHub.com to book a consultation.

Written by the CnBusinessHub Advisory Team, China market-entry advisors since 2019 — 1,500+ foreign enterprises guided across 16+ cities.

Last updated: 2026-10-11 | Next review: April 2027

Sources

1. National Laws and Regulations Database — Price Law of the PRC
2. SAMR — Provisions on Clearly Marking Prices and Prohibiting Price Fraud (Decree No. 56), Full Text
3. Ministry of Justice — Provisions on Clearly Marking Prices and Prohibiting Price Fraud, Full Text
4. National Administrative Regulations Database — Provisions on Administrative Penalties for Price Violations (2010 Third Revision)
5. SAMR — Key Points Interpretation of the Provisions on Clearly Marking Prices and Prohibiting Price Fraud
6. SAMR — Announcement of the Provisions on Clearly Marking Prices and Prohibiting Price Fraud

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