Keywords
Consumer rights protection
Legal comparison of China, Japan, and the Republic of Korea
Regional cooperation
Rights protection challenges
Submitted : 2026-03-16
Accepted : 2026-03-31
Published : 2026-04-15
Abstract
Against the backdrop of regional economic integration in East Asia and the rapid development of cross-border e-commerce, the scale of online cross-border consumption in China, Japan, and the Republic of Korea continues to rise, with issues such as jurisdictional conflicts in cross-border consumer rights protection, excessively high costs, and difficulties in evidence collection becoming increasingly prominent. This paper employs a comparative analysis approach to systematically examine the legal systems and core institutions for cross-border consumer rights protection in the three countries, compare their similarities and differences as well as advantages and disadvantages, and delve into the underlying causes of difficulties in rights protection. From two dimensions—domestic legislative optimization and regional collaboration—the paper proposes targeted and feasible solutions. The study reveals that while the legislative philosophies of the three countries are convergent, significant differences exist in institutional details. Only by addressing legislative shortcomings and establishing a transnational rights protection collaboration mechanism can the challenges in cross-border rights protection be overcome, consumer rights and interests be safeguarded, and the healthy development of cross-border trade among the three countries be promoted.
References
Li SZ, 2011, Comparative Study and Implications of E-commerce Legal Environments in China, Japan, and the Republic of Korea. Research on Business Economics, 2011(23): 126–127.
Round DK, Sporer Z, 2003, Globalisation and Consumer Protection in East Asia: Is It a Zero Sum Game? Asian-Pacific Economic Literature, 18(1): 1–18.
Lee SJ, 2018, Comparative Study on Consumer Rights Protection Systems in Cross-border E-commerce between China and the Republic of Korea, thesis, Shandong University.
Sun YL, 2020, Research on Legal Application Issues of Foreign Consumer Contracts in Japan, thesis, Dalian Maritime University.
Tan MW, 2023, RCEP Online Consumer Protection Clauses and China’s Response. Business Economics, 2023(5): 112–115.
Su HP, Guo JJ, 2017, On the Unification of Contract Law Application for East Asian Consumers. Political Science and Law Forum, 2017(6): 38–46.
Zhu T, 2017, Functional Attributes Analysis of Article 25 of the Consumer Rights Protection Law: Insights from Japanese Experience. Journal of Beihang University (Social Sciences Edition), 30(3): 45–52.
Ye ZX, 2023, Legal Conflicts and Application Exploration in Consumer Rights Protection in Cross-border E-commerce: A Perspective on Platform Liability. E-commerce Review, 12(5): 1–8.
Dong XY, 2021, A Strengthened Financial Consumer Protection Act: A Review of the Republic of Korea’s Financial Consumer Protection Act. Hebei Law Journal, 39(2): 103–118.
Gu XR, Hu CJ, Chen L, 2012, Preliminary Study on Criminal Law Protection of Financial Consumers in China and Japan. Politics and Law, 2012(6): 123–131.
Trilateral Cooperation Secretariat, 2019, Trilateral Cooperation “Joint Study on E-Commerce” Executive Summary. Trilateral Cooperation Secretariat, Seoul.
Elms D, 2020, Evolving Digital and E-Commerce Trade Rules for Northeast Asia. The Republic of Korea Institute for International Economic Policy (KIEP), Seoul.
Takasugi N, 2014, E-Commerce Law and the Prospects for Uniform E-Commerce Rules on the Privacy and Security of Electronic Communications. Arizona Journal of International and Comparative Law, 31(2): 257–282.
Ide R, 2011, Trademark Act and Consumer Protection with a Focus on a Comparative Study of the Sign Systems in Japan, China, and the Republic of Korea. Institute of Intellectual Property, Tokyo.
Habuka H, Rule C, 2019, The Promise and Potential of Online Dispute Resolution in Japan. International Journal of Online Dispute Resolution, 6(2): 32–47.
Guo MA, 2012, Comparative Study on Consumer Right to Privacy in E-Commerce. Modern Economy, 3(4): 468–473.
Marcus JS, Petropoulos G, Jitsuzumi T, 2015, Strengthening E-commerce in the Asia-Pacific Region: Opportunities and Challenges. 14th Asia-Pacific Regional Conference of the International Telecommunications Society.
Monteiro J, Teh R, 2017, Provisions on Electronic Commerce in Regional Trade Agreements. WTO Staff Working Paper ERSD-2017-10, 2017.
Basu S, Jones R, 2005, Development of Information and Technology Law in Asia. International Review of Law, Computers & Technology, 19(2): 129–137.
Zhang C, Zhang XY, Cao TF, et al., 2025, International Experience in Credit Complaint Handling and its Implications for China. China Credit Information, 2025(12): 45–52.