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legal 2026.03.31 12 min read

Thailand's E-Commerce Product Safety Enforcement Accelerates: TISI Certification, High-Risk Product Lists, and Takedown Obligations

Thailand's ETDA Section 18(2) Notification (effective December 31, 2025), TISI/FDA high-risk product list, and four-agency joint enforcement are reshaping product safety requirements on Thai online marketplaces. This article explains what Japanese sellers and platform operators need to know.

Product safety regulation is tightening rapidly on Thailand’s online marketplaces. On December 31, 2025, the ETDA (Electronic Transactions Development Agency) notification under Section 18(2) took effect, imposing obligations on designated marketplace platforms covering seller identity verification, product information disclosure, and takedown mechanisms for non-compliant products. In March 2026, four government bodies — the Thailand Consumers Council, TISI, ETDA, and OCPB — jointly announced an intensified enforcement push with the clear message of clearing dangerous products from online platforms. For Japanese companies selling through Shopee, Lazada, and other Thai marketplaces, these developments have direct practical implications.

The legal foundation for this regulatory push is the Royal Decree on Digital Platform Service Businesses B.E. 2565 (2022), supervised by ETDA. Section 18(2) of the Royal Decree grants the Electronic Transactions Committee authority to impose additional measures on platform operators.

Exercising this authority, ETDA issued the notification “Notification of the Electronic Transactions Committee Re: Other Actions for Digital Platform Service Operators in the Category of Marketplace for Goods with Specific Characteristics under Section 18(2) B.E. 2568” on July 9, 2025, with an effective date of December 31, 2025 (180 days after publication).

The notification applies to marketplace operators designated by ETDA. At the time of publication in July 2025, 19 platforms were designated, with additional designations bringing the total to 21 (including Shopee, Lazada, Grab, Line Shopping, Alibaba, and others). The current list is available on the ETDA official website.

Platform Operator Obligations — Five Pillars

The Section 18(2) Notification imposes the following obligations on designated marketplace operators.

① Seller Identity Verification

Platforms must collect and verify identifying information — including name, address, phone number, email address, and bank account details — from sellers offering products regulated by TISI or FDA, prior to listing. Sellers must submit a self-certification of regulatory compliance. This requirement aligns with the OCPB’s e-KYM (Know Your Merchant) policy.

② Product Information Display

Listings must clearly display product names, images, key descriptions, and — critically — TISI certification marks with license numbers or FDA approval numbers. The joint four-agency announcement specifies that sellers must display the TISI certification mark and license number on their primary product image, with non-compliance potentially subject to fines and imprisonment.

③ Notice and Takedown Mechanism

Platforms must establish a mechanism for users and regulatory authorities to report illegal or dangerous products. Upon receiving a report, the platform must notify the seller and suspend the listing pending investigation. The four-agency joint announcement emphasizes the obligation for platforms to respond promptly when TISI, OCPB, or ETDA identifies non-compliant products (the specific time requirement should be verified against official notifications).

④ Regulatory Cooperation and Annual Reporting

Platforms must provide seller information to TISI and FDA upon request and submit annual reports to ETDA covering the number of regulated product listings, sellers, removed listings, and complaints.

⑤ TISI API Integration (Planned for 2026)

The four-agency announcement calls for platforms to connect to the TISI database via API to automatically verify product certification status before listing. An August 2026 implementation deadline has been reported — however, this timeline has not been independently confirmed in official ETDA or TISI publications as of the time of writing, and official announcements should be monitored. Platforms that cannot complete API integration by the deadline would be required to implement alternative seller identification and tracking mechanisms; where sellers cannot be identified, platforms may share liability for consumer compensation.

TISI/FDA High-Risk Product List

On December 30, 2025, ETDA jointly published a High-Risk Product List with TISI and FDA. Designated platforms must prioritize screening based on this list.

TISI-regulated products on the list include (confirmed): hair dryers, power strips, mobile power banks, adapters, HVAC fans, electrical wire, motorcycle helmets, rice cookers, washing machines and dryers, air conditioners, electric cookers and air fryers, electric water heaters, microwave ovens, LED lamps, LED luminaires, residual current devices (RCDs), irons, air purifiers, tempered glass, food packaging film, crayons, various toys, vehicle and motorcycle tires, seat belts, lighters, non-stick cookware, melamine tableware, baby bottle nipples, and more. Standards for EV-related products are also reportedly being developed.

FDA-regulated products include prescription drugs (excluding general household medicines), controlled herbal products, narcotics and psychotropic substances, and medical devices requiring prescriptions or for use in medical facilities.

The complete list can be found on the ETDA (https://www.etda.or.th/) and TISI official websites.

Impact on Japanese Sellers — Is TISI Certification Required?

The answer depends on your product category.

Japanese manufacturers producing and selling electrical products in Thailand are subject to mandatory TISI certification (compulsory standards) under the Industrial Product Standards Act for products falling within the scope of those standards. Many products on the high-risk list fall under TISI compulsory standards. Certification marks and license numbers must be displayed on product images.

Companies importing electrical products from Japan to sell via Thai e-commerce are equally subject to TISI certification requirements for imported products. Non-compliance risks include listing suspension or removal, plus potential penalties (fines and imprisonment) under the Industrial Product Standards Act.

Companies handling food, cosmetics, or pharmaceutical products fall under FDA jurisdiction. FDA approval and registration numbers must be verified and displayed even for online sales.

Companies operating as platform operators are directly subject to all of the above obligations. Urgent priorities include building seller verification systems, implementing TISI/FDA-based screening processes, establishing removal and reporting procedures, and preparing for TISI API integration.

OCPB Registration and Consumer Protection

Platform operators engaged in direct marketing activities may need to register with the OCPB (Office of the Consumer Protection Board) and provide a surety bond under the Direct Sales and Direct Marketing Act B.E. 2545 (2002). The four-agency announcement noted that platforms that knowingly allow non-compliant products may face business registration cancellation.

Lemon Law — Consumer Rights for Defective Products Coming to Thailand

The OCPB is advancing legislation commonly referred to as the “Lemon Law Bill,” formally titled the “Liability for Defective Products Act.” This proposed law would establish consumer rights to immediate repair, replacement, or refund for defective or dangerous products. As of March 2026, the bill is still under OCPB review following public hearings completed in 2024, and has not yet been submitted to cabinet or parliament. The timing of enactment remains uncertain, but e-commerce operators are well advised to review and strengthen their returns and replacement policies in anticipation.

Action Checklist for Japanese Sellers

Determine whether your products are subject to TISI compulsory standards — check the TISI Compulsory Standards List

Initiate TISI certification procedures if required — certification takes time; early action is essential

Display TISI certification marks and license numbers on product listings — display on the primary product image is required

For FDA-regulated products, verify and display FDA approval/registration numbers

Monitor platform policy updates and notifications — listing rules may change as platforms implement TISI API integration

Strengthen your returns and replacement policy — in anticipation of the Lemon Law

Check OCPB registration requirements — assess whether your activities constitute direct marketing

For the broader e-commerce regulatory landscape, see our articles on TCCT’s fee and logistics guidelines and Digital Law Series Part 4 (ETDA Royal Decree legal framework). Companies exporting products to Thailand through cross-border e-commerce should also review the implications of Thailand’s abolition of customs de minimis exemptions effective January 2026.

For advice on product safety compliance in Thailand’s e-commerce market, TISI certification procedures, and platform regulatory compliance — covering both Japanese and Thai law — please contact us.

This article is based on publicly available information as of March 2026 and is intended for general informational purposes only. It does not constitute legal advice under Thai law. For specific matters, please consult a Thai-qualified legal professional. Our firm works in collaboration with JTJB International Lawyers’ Thai-qualified attorneys.

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