In general, according to China’s Consumer Rights Protection Law (Art. 23) and Product Quality Law (Art. 40), it is the responsibility of the operators, which includes the importer and/or distributor, as well as the manufacturer.

The Chinese consumer (buyer) seeks compensation from the operator which is legally based in China (usually, the importer or the distributor), through different means such as amicable negotiations, or legal action/arbitration if necessary (incl. through consumers’ rights protection associations and relevant market supervision authorities). Eventually, the operator (importer or distributor) will seek compensation from the manufacturer, through means which are normally regulated in the sales contract in place. This includes possible legal action/arbitration. If the manufacturer has no legal entity (or any assets) in China, of course it will be difficult for Chinese consumers and courts to enforce their decisions, they have to go through courts where the manufacturer has a legal entity or has assets.

In any case, if the manufacturer refuses to cooperate, its future sales/operations in China will be negatively affected (e.g. products not cleared at the customs; inclusion in negative lists of relevant market supervision authorities, etc).