Legal Regulation of Electronic Commerce Relations in Uzbekistan and China: Comparative Legal Perspectives on Platform Liability, Consumer Protection and Digital Compliance
Keywords:
electronic commerce; comparative law; Uzbekistan; China; business law; platform liability; consumer protection; personal data; digital payments; cross-border tradeAbstract
This article examines the legal regulation of electronic commerce relations in Uzbekistan and China from a comparative legal perspective. Using the functional method of comparative law with normative and institutional analysis, it compares how the two systems address electronic contracts, consumer protection, platform liability, personal data and electronic payments. It argues that Uzbekistan has built a solid foundation through the Law on Electronic Commerce (2022) and related legislation, but that platform operator liability, online consumer remedies, algorithmic transparency and the supervision of new payment products still require more detailed regulation. China's E-Commerce Law, Personal Information Protection Law and payment rules offer instructive techniques that must be adapted to Uzbek conditions rather than transplanted mechanically. The article concludes that a balanced model should combine legal certainty, platform accountability, consumer trust and risk-based supervision.
References
1. Civil Code of the People's Republic of China. (2020). National People's Congress of the People's Republic of China.
2. E-Commerce Law of the People's Republic of China. (2018). National People's Congress of the People's Republic of China.
3. European Parliament and Council. (2016). Regulation (EU) 2016/679 (General Data Protection Regulation). Official Journal of the European Union, L 119.
4. Law of the Republic of Uzbekistan No. LRU-792 'On Electronic Commerce.' (2022, September 29). National Database of Legislation of the Republic of Uzbekistan.
5. Law of the Republic of Uzbekistan No. LRU-793 'On Electronic Digital Signature.' (2022, October 12). National Database of Legislation of the Republic of Uzbekistan.
6. Law of the Republic of Uzbekistan 'On Electronic Document Management.' (2004, April 29). National Database of Legislation of the Republic of Uzbekistan.
7. Law of the Republic of Uzbekistan 'On Payments and Payment Systems.' (2019, November 1). National Database of Legislation of the Republic of Uzbekistan.
8. Law of the Republic of Uzbekistan 'On Personal Data.' (2019, July 2). National Database of Legislation of the Republic of Uzbekistan.
9. OECD. (2016). Consumer protection in e-commerce: OECD recommendation. Organisation for Economic Co-operation and Development.
10. Personal Information Protection Law of the People's Republic of China. (2021). National People's Congress of the People's Republic of China.
11. Regulation on the Supervision and Administration of Non-Bank Payment Institutions of the People's Republic of China. (2024). State Council of the People's Republic of China.
12. UNCITRAL. (1996). UNCITRAL Model Law on Electronic Commerce with Guide to Enactment. United Nations.
13. UNCITRAL. (2001). UNCITRAL Model Law on Electronic Signatures with Guide to Enactment. United Nations.
14. Wang, L. (2020). Platform governance and consumer protection under China's ECommerce Law. Tsinghua China Law Review, 12(2), 85–118.
15. Zhang, Y. (2022). Personal information protection and automated decision-making in Chinese digital markets. Computer Law & Security Review, 45, 105–124.
