Summary

• The Commission has accepted five corrective measures following its May 2026 decision against Temu.
• The plan addresses platform-specific risk analysis, mitigation metrics, moderation weaknesses, recommendations and deliberate manipulation.
• Temu must conduct an interim assessment within four months, followed by independent scrutiny; approval of the plan is not proof of compliance.

The European Commission has accepted a corrective action plan from Temu following a €200 million penalty for failures to assess the risks posed by illegal products on its marketplace, shifting the regulatory case towards implementation and independent scrutiny.

The plan, accepted on 26 October, contains five measures intended to address deficiencies identified under the EU Digital Services Act (DSA). Temu must conduct an assessment specific to its platform, develop reliable measures of risk mitigation, examine weaknesses in moderation, and investigate how recommendation systems and deliberate manipulation may increase exposure to illegal goods.

The Commission fined Temu in May after concluding that its previous assessment underestimated the likelihood of European consumers encountering illegal products. The finding concerned the company’s failure to examine systemic risks adequately, including the influence of its own marketplace design.

Acceptance of the plan does not reverse the penalty or establish that the underlying risks have been resolved. Temu has four months to complete an interim risk assessment covering a six-month period ending on 30 November 2026, while implementation of the corrective measures will be subject to further examination.

Platform evidence replaces generic assessments

The original enforcement decision identified a fundamental weakness in Temu’s approach to regulatory compliance. Its 2024 risk assessment drew heavily on general information about the e-commerce industry, rather than evidence about how illegal products could be distributed through Temu’s particular service.

That distinction is important because marketplaces differ in their seller arrangements, promotional systems, catalogue structures and methods for identifying problematic listings. Controls that work within one service may be inadequate where another platform creates different incentives or opportunities for abuse.

The Commission’s investigation included product testing that raised concerns about selected electrical chargers and children’s toys. Some chargers failed basic safety requirements, while certain toys presented hazards associated with chemical content or detachable parts.

These findings provided evidence that the shortcomings were not confined to administrative documentation. They concerned the conditions under which European shoppers could encounter goods that did not meet applicable safety requirements.

Under the accepted plan, Temu must analyse the characteristics of its own marketplace and use suitable indicators to measure whether protective measures are effective. That requires more than recording how many suspicious listings moderators have removed.

A large volume of removals might indicate that a platform is detecting significant numbers of problematic products, but it does not establish how frequently consumers encountered them before action was taken. Conversely, fewer removals could reflect improved prevention or deteriorating detection.

Assessments therefore need to account for the visibility and persistence of risky listings, the effectiveness of seller controls, and the likelihood that previously identified products reappear through different accounts.

Recommendations become part of product safety

One of the most consequential elements concerns Temu’s recommendation and promotional systems. An online marketplace does not merely display products supplied by sellers; it influences which listings receive attention through ranking, personalisation and promotional features.

Those mechanisms are designed to help consumers discover goods and support commercial activity, but they can also increase exposure to products that should not be available. A problematic listing promoted extensively before removal may create a greater risk than one that receives little visibility.

The Commission has required Temu to examine whether its recommendation systems contribute to the spread of illegal goods and how marketplace features could be manipulated by sellers or other parties.

Such an assessment requires cooperation between compliance specialists, moderation teams and engineers responsible for search, ranking and commercial recommendations. Measures introduced only after a product has been reported may fail to address the mechanisms that contributed to its earlier distribution.

Temu must also evaluate limitations in its moderation arrangements, rather than assuming that a system is effective because it processes substantial numbers of reports or enforcement decisions.

These obligations illustrate how European regulation is extending responsibility beyond responding to individual complaints. Design choices made within a platform can influence systemic risks, even where the goods themselves originate with independent sellers.

Implementation remains open to scrutiny

The corrective process followed the Commission’s May 2026 finding that Temu had failed to meet its DSA risk assessment obligations. The company subsequently submitted measures intended to remedy that infringement.

The European Board for Digital Services examined the proposed response before the Commission accepted the plan. The resulting process has involved clarification of the requirements against which Temu’s actions will be assessed.

The company must now produce an interim assessment within four months. An independent external audit will examine the measures after implementation, providing a further opportunity to test whether processes described in the plan operate effectively.

A regulatory authority’s acceptance of corrective proposals is different from concluding that those proposals have already delivered satisfactory results. The relevant evidence will include whether the platform has established dependable measurements, identified genuine weaknesses and changed the processes responsible for unacceptable exposure.

Temu has welcomed acceptance of the plan, but the company has not published evidence demonstrating that all five measures have been implemented successfully.

The outcome also has implications for other large marketplaces operating in Europe. Risk assessments must reflect the characteristics of individual services, rather than relying on general assurances that industry-standard moderation and product safety processes are in place.

For operators, that can require more detailed data collection, closer examination of recommendation systems and stronger coordination between engineering, commercial and compliance functions. The resulting work is not necessarily limited to legal reporting: it may require changes to how a platform identifies sellers, ranks listings and monitors product categories.

The DSA establishes obligations concerning the assessment and mitigation of systemic risks, but it does not guarantee that every individual illegal product will be intercepted before reaching a consumer. Effective enforcement depends on whether operators can identify and reduce the risks created by their services.

Temu’s next interim assessment and subsequent independent audit will provide the evidence against which the Commission can judge progress. Until those results are available, the accepted plan remains a commitment to corrective action rather than proof that the marketplace has resolved the failures identified in May.