EU Accepts Temu's DSA Plan Following €200 Million Fine

Have you ever ordered an item from a cross-border platform, received it, and wondered: \"Is this item truly as safe as advertised?\" That is not just your personal concern. That is the question an entire regulatory system worth hundreds of millions of euros is trying to answer.

And recently, that answer reached a new milestone: the EU accepts Temu's DSA plan – a move marking a turning point in the confrontation between the European Union and the cross-border e-commerce giant from China.

But do not celebrate just yet. This is not a happy ending. This is a new test, where Temu must prove that it is truly changing, rather than just submitting a well-written plan on paper.

EU Accepts Temu's DSA Plan: A \"Handshake\" After a €200 Million Fine

Let us step back a bit to understand the context. In May 2026, the European Commission confirmed preliminary findings from July 2025 and fined Temu €200 million for failing to fulfill risk assessment obligations under Article 34 of the Digital Services Act (DSA) – specifically regarding risks related to the dissemination of illegal products on its e-commerce marketplace.

Put simply: the EU argued that Temu did not do enough to identify, analyze, and assess the risks its platform could pose to European consumers. And the €200 million fine was a stern warning.

Following that, in August 2026, Temu submitted an action plan to the Commission to address these shortcomings. And on October 26, 2026, the Commission officially accepted Temu's DSA plan, marking the start of a new phase: the enforcement phase.

Five Measures: When Temu Must \"Dissect\" Itself

What is noteworthy is that Temu's plan is not just an empty promise. It includes five specific measures, each targeting a vulnerability in the platform's risk assessment system.

First, Temu commits to conducting a tailored risk assessment for its platform, using reliable and up-to-date information to identify specific risks related to the design, operation, and usage of the platform. This is the foundation of all subsequent measures: if you do not understand your own risks, you cannot control them.

Second, Temu must use reliable metrics and indicators to assess whether the implemented mitigation measures are truly effective in reducing the risk of disseminating illegal content. No more generic reports. There must be numbers. There must be evidence.

Third, Temu must assess and explain the limitations of its proactive content moderation systems – including the impact of these systems on recommended products. This means Temu cannot simply say \"we have a moderation system.\" They must prove that the system actually works and point out its weaknesses.

Fourth, Temu must analyze how recommendation systems and other algorithmic systems can affect and amplify the dissemination of illegal content. This is an extremely critical point. Recommendation algorithms can unintentionally push illegal products closer to users. Temu must prove that it understands and controls this.

Fifth, Temu must examine the role of intentional manipulation – including how sellers can exploit Temu's features to disseminate illegal product listings. This is an acknowledgment that not only the platform, but also sellers on the platform, can be sources of risk.

A Four-Month Deadline and Independent Audit: Will It Be Enough?

Under the approved plan, Temu has four months to implement the action plan. During this time, it must conduct an interim risk assessment spanning six months, running until November 30, 2026.

Even more noteworthy is the requirement for an independent audit. Temu has committed to conducting an external and independent audit to evaluate its measures. The audit report must be submitted to the Commission within four months after implementing the measures. And if the auditor makes recommendations, Temu must report back to the Commission within one month on the implementation of those recommendations.

This is a rigorous monitoring mechanism. It does not allow Temu to evaluate itself and conclude that everything is fine. An independent third party must confirm that what Temu is doing is sufficient.

What Does the Board for Digital Services Say? Unfilled Gaps

It is worth noting that Temu's plan was not approved lightly. The Board for Digital Services – the EU's independent advisory body – was consulted and issued its opinion on September 24.

What was the Board's opinion? The Board considered the proposed changes to be \"partially appropriate,\" but the plan \"lacked sufficient level of detail\" to fully assess whether it adequately addressed the infringement.

This is a notable criticism. It means that even though the plan has been accepted, gaps remain that the Commission must clarify. The Commission stated that it has considered the Board's opinion and clarified key requirements that Temu must address during the implementation of the action plan.

In other words, this is not an unconditional approval. This is a supervised approval, where the Commission will \"closely monitor\" Temu's implementation, paying special attention to issues that the Board felt were not fully explained and require additional information.

What Does This Mean for Consumers and Sellers?

For European consumers, this is a positive signal. The approved plan means Temu will be more accountable for ensuring that products on its platform are safe and legal. If Temu fails to fulfill its commitments, it could face additional sanctions.

At the same time, consumers must also understand that a plan is not an outcome. What is written on paper does not automatically become reality. The four-month timeframe and independent audit process will be the real test.

For sellers on Temu, this is a reminder that regulations are becoming increasingly strict. Sellers who comply with the law will benefit from a fairer playing field. But sellers who rely on illegal products or loopholes will face mounting pressure.

Lessons for Cross-Border E-commerce

Temu's story is not an isolated incident. It is part of a broader trend: regulators are tightening control over cross-border e-commerce platforms.

For years, platforms like Temu, Shein, and AliExpress took advantage of regulatory gaps to grow rapidly. But as the DSA takes effect, those gaps are gradually closing. Platforms are forced to take responsibility for the content and products on their platforms, not just formally, but substantively.

For Vietnamese businesses operating or planning to expand into Europe, this is an important lesson: legal compliance is no longer an option, but a prerequisite for survival. Investing in risk assessment systems, content moderation, and process transparency is not a cost – it is an investment in sustainability.

When Trust Must Be Proven, Not Just Declared

I have witnessed the e-commerce industry go through many revolutions over the past two decades. From the days when online shopping was a gamble, to an era where consumers can order from the other side of the globe with just a few clicks. Each step forward brings new opportunities, but also raises new questions about responsibility and trust.

The EU accepting Temu's DSA plan is not the end of concerns regarding illegal goods on cross-border platforms. It is a new beginning, where promises must be proven by actions, and commitments must be verified by independent data.

And in a world where consumers are increasingly savvy and regulators are increasingly strict, trust cannot simply be declared. It must be built day by day, through concrete actions and measurable results.

When shopping on cross-border platforms, where do you place your trust – in the platform's reputation, in reviews from previous buyers, or in consumer protection regulations? And if you are a seller on a platform like Temu, what will you prepare to not only comply with tightening regulations, but also turn that compliance into a competitive advantage? Share your thoughts below, because in this cross-border e-commerce game, the one who understands the rules best will be the winner!