MECHANISM FOR HANDLING CONSUMER COMPLAINTS AGAINST OPERATORS OF ELECTRONIC TRADING PLATFORMS: A COMPARATIVE LEGAL ANALYSIS OF THE EXPERIENCE OF CHINA AND UZBEKISTAN

Abstract

This article presents a comparative legal analysis of consumer complaint mechanisms against e-commerce platform operators in the People's Republic of China and the Republic of Uzbekistan. The study is prompted by the rapid growth of Uzbekistan's e-commerce market, accompanied by a sharp rise in consumer complaints from 1,328 in 2024 to 3,100 in 2025 and 1,657 in the first quarter of 2026 alone. The research employs comparative legal and formal-doctrinal methods. The empirical basis consists of official data from China's State Administration for Market Regulation (SAMR) for 2025 and Uzbekistan's Committee for the Development of Competition and Protection of Consumer Rights for 2024–2026. The analysis is structured around four criteria: the institutional architecture of complaint mechanisms, the normative clarity of operator obligations, measurable enforcement effectiveness indicators, and the platform liability regime. The study finds that China's three-tier model a mandatory in-platform complaint mechanism, the state-integrated 12315 ODR platform, and an administrative-judicial tier resolved 12.33 million disputes in 2025 without the involvement of the state regulator. Uzbekistan's system, by contrast, lacks this primary platform-level tier, leading to a growing regulatory burden on the Committee. The failure of the EU's voluntary ODR platform, closed in 2024 due to low operator uptake, further demonstrates that mandatory operator participation is a critical condition for systemic effectiveness. Empirical analysis is grounded in the documented Uzum Market/Oila Tanlovi case (2024–2025), which progressed through all judicial instances and clearly exposed the gap in Uzbek law regarding operator liability for goods sold under the platform's own private label. The article proposes four interconnected additions to the Law on Electronic Commerce (ZRU-792): Article 13-1 (mandatory in-platform complaint mechanism), Article 13-2 (functional operator liability), Article 16-1 (public offer disclosure standards), and Article 28-1 (state ODR platform). The proposed norms are compatible with Uzbekistan's Civil Code and require no amendments to the fundamental provisions of civil law.