OCPB: National Action Plan on Online Products Signals More Coordinated Regulatory Oversight

Thailand is moving toward a more coordinated approach to regulating products sold through online channels. The Office of the Consumer Protection Board (OCPB) is leading the development of a National Action Plan (NAP) on online products following a nationwide public consultation process. The initiative aims to strengthen cooperation among government agencies responsible for consumer protection, product safety, intellectual property, customs, taxation, digital platforms, and law enforcement.

Although the National Action Plan is still under development, it signals the government’s intention to enhance oversight of online commerce through coordinated enforcement rather than relying on individual regulators acting independently. Businesses participating in Thailand’s digital marketplace should closely monitor these developments and consider reviewing their compliance frameworks in anticipation of increased regulatory cooperation.

A Coordinated Regulatory Framework:

The proposed National Action Plan is intended to establish an integrated framework for addressing issues associated with products sold online. Rather than creating an entirely new regulatory regime, the initiative seeks to improve cooperation, information sharing, and joint enforcement among relevant authorities.

Its objectives include:

• strengthening consumer protection in online commerce;
• reducing the circulation of counterfeit, unsafe, and non-compliant products;
• improving coordination among regulatory and enforcement agencies;
• enhancing traceability within online supply chains; and
• promoting confidence in Thailand’s digital economy.

If implemented as proposed, the framework would enable authorities to respond more efficiently to unlawful online activities by combining investigative resources and sharing information across agencies.

A Broad Regulatory Focus:

The proposed framework extends beyond intellectual property enforcement. Authorities have indicated that the initiative is intended to address a broad range of consumer protection and regulatory concerns relating to products sold online.

Areas expected to receive greater attention include:

• products that fail to meet mandatory safety standards;
• cosmetics, food, medical devices, and health products marketed without required approvals;
• prohibited or restricted goods;
• misleading or deceptive product claims;
• goods imported in violation of customs requirements; and
• products sold in breach of consumer protection laws.

Businesses should therefore view the initiative as a comprehensive regulatory effort affecting multiple areas of compliance rather than solely an anti-counterfeiting measure.

Implications for Online Platforms:

Online marketplaces and social-commerce platforms are likely to face increased expectations regarding their governance of third-party sellers and product listings.

As regulatory cooperation expands, platforms may be expected to strengthen:

• seller verification procedures;
• mechanisms for removing unlawful listings;
• monitoring of higher-risk products;
• cooperation with government investigations; and
• recordkeeping to support regulatory enforcement.

Platforms with effective compliance systems and transparent governance practices are likely to be better positioned as regulatory expectations evolve.

Considerations for Online Sellers:

Online sellers should ensure that products offered through digital channels comply with all applicable regulatory requirements.

Businesses should review whether regulated products possess the necessary registrations, approvals, certifications, or licenses. Marketing materials, product descriptions, pricing information, and labeling should also be assessed to ensure compliance with consumer protection requirements.

Businesses importing products into Thailand should also verify that customs documentation and import procedures are properly maintained, particularly if enforcement activities become more coordinated across agencies.

Logistics Providers and Payment Service Providers:

The proposed National Action Plan recognizes that effective enforcement may require cooperation from businesses supporting online transactions.

Logistics providers may receive requests from authorities to assist in tracing the movement of goods associated with unlawful online sales.

Similarly, payment service providers may be asked to cooperate in investigations involving transactions connected with illegal products or fraudulent online businesses.

Maintaining appropriate compliance procedures and responding promptly to lawful requests from competent authorities will remain important risk management measures.

Opportunities for Brand Owners:

For brand owners, the proposed framework may strengthen enforcement against counterfeit and infringing products sold online.

Closer coordination among consumer protection authorities, customs officials, intellectual property agencies, and law enforcement may facilitate more effective action against repeat offenders and organized distribution networks.

Nevertheless, businesses should continue monitoring online marketplaces, preserving evidence of infringement, utilizing platform reporting mechanisms, and pursuing civil or criminal remedies where appropriate.

Preparing for a More Coordinated Enforcement Environment:

Although the National Action Plan has not yet been finalized, businesses should consider reviewing their compliance programs in anticipation of increased regulatory cooperation.

Practical steps include:

• conducting compliance reviews of products sold online;
• strengthening seller onboarding and verification processes;
• maintaining documentation demonstrating regulatory compliance;
• reviewing procedures for responding to regulatory requests;
• establishing effective complaint-handling and takedown procedures; and
• providing compliance training for employees responsible for online sales and marketplace operations.

Early preparation may help businesses reduce regulatory risks once the coordinated framework is implemented.

Key takeaways:

• The Office of the Consumer Protection Board is leading the development of a National Action Plan on online products following a nationwide consultation process.
• The initiative is intended to strengthen coordination among agencies responsible for consumer protection, product safety, customs, taxation, intellectual property, and law enforcement.
• The proposed framework extends beyond counterfeit goods to address broader regulatory and consumer protection issues relating to online product sales.
• Online marketplaces, sellers, logistics providers, payment service providers, and brand owners should expect greater regulatory cooperation and more coordinated enforcement.
• Businesses should review and strengthen their compliance programs in preparation for the evolving regulatory land

Author: Panisa Suwanmatajarn, Managing Partner

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