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Why Shein has extra obligations under the DSA
The VLOP threshold
The European Commission designated Shein a very large online platform (VLOP) on 26 April 2024. The DSA’s threshold is more than 45 million average monthly users in the EU. At designation, the Commission said Shein had communicated that it was above that threshold. The figure explains why the rules apply; it is not a current user count or a finding of wrongdoing.
The additional obligations were due within four months of notification, by the end of August 2024. VLOP status attaches because of a platform’s scale. It does not, by itself, mean that the platform has violated the DSA.
What the added duties require
The Commission’s DSA guidance says VLOPs must identify and assess systemic risks associated with their services and take steps to mitigate them. The duties include:
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- Assessing risks such as the spread of illegal content and effects on fundamental rights, consumer protection, children’s rights, public security, public health, and mental and physical wellbeing.
- Putting appropriate risk-mitigation measures in place and maintaining an internal compliance function.
- Undergoing an independent audit at least once a year and sharing relevant data with the Commission and national authorities.
- Giving vetted researchers access to relevant data for systemic-risk research.
- Offering users at least one easily accessible recommender-system option that is not based on profiling, and keeping a public repository of advertisements.
In its designation announcement, the Commission highlighted risks involving illegal products, including counterfeit, unsafe and intellectual-property-infringing goods. It said possible mitigation could include reporting and detection tools, moderation processes, interface changes and algorithm refinements. It also called for attention to consumer health and safety, particularly for minors, as well as transparency reporting and annual independent audits.
Why published user figures differ
The Commission’s designated-platform list, updated in 2026, reports 108 million average monthly active users for Shein; the page describes such figures as provider-reported and without prejudice to the Commission’s assessment. Separately, Shein reported 127.9 million average monthly active users for 1 February through 31 July 2026 in its own DSA disclosure. Those figures come from different publishers and reporting contexts, so they should not be combined into a single trend. Neither changes the fact that the 2024 designation was based on the threshold information then communicated.
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What the Commission’s DSA investigation examines
On 26 November 2025, the Commission sent Shein a further request for information after preliminary indications that illegal goods, including child-like sex dolls and weapons, had been offered on its marketplace. On 17 February 2026, it opened formal DSA proceedings focused on three areas:
Controls on illegal products
The Commission is examining whether Shein’s systems limit the sale of illegal products in the EU, including listings or content that could constitute child sexual abuse material, such as child-like sex dolls.
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Potentially addictive design
The Commission is examining risks it associates with features such as points or rewards for user engagement, and whether Shein has systems to assess and mitigate those risks. The Commission has said such features could negatively affect wellbeing and consumer protection; that is its stated concern, not an established impact finding.
Recommender transparency
The Commission is examining whether Shein explains the main parameters of its recommender systems and provides, for each system, at least one easily accessible option that does not rely on profiling.
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Opening formal proceedings does not prejudge the outcome. The Commission’s supervision chronology, updated 31 August 2026, lists the February opening and no later Shein DSA disposition. As of 8 October 2026, the published chronology therefore shows an open proceeding, not a final DSA decision.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How the separate consumer-law action differs
The Consumer Protection Cooperation Network (CPC Network) and the Commission notified Shein on 26 May 2025 of practices they assessed as potentially infringing EU consumer law and asked the company to bring them into line. The action is based on consumer-law rules, including the Unfair Commercial Practices Directive, Consumer Rights Directive, Price Indication Directive and e-Commerce Directive. It is distinct from the Commission’s DSA investigation.
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The network’s notification raised concerns about fake discounts that were not based on actual prior prices; false deadlines used to pressure shoppers; incomplete or misleading returns and refund information; deceptive product labels; misleading sustainability claims; and contact details that were difficult to find. Authorities also sought information about the presentation of rankings, reviews and ratings, and about how consumers are told which responsibilities lie with Shein and which with third-party sellers. These were the authorities’ assessments and inquiries, not a final court ruling.
The Commission’s consumer-action status page says the coordinated action remains ongoing. It says authorities may take enforcement measures if Shein does not address the concerns. On 26 May 2025, Commissioner for Democracy, Justice, the Rule of Law and Consumer Protection Michael McGrath said: “All companies reaching out to EU consumers must play by our rules. Today’s action sends a clear message: we will not shy away from holding e-commerce platforms to account, regardless of where they are based. EU consumer protection laws are not optional —they must be applied in all cases. I strongly welcome the decisive action taken by the CPC Network. It’s now for SHEIN to step up, respect the rules and bring its practices fully in line with EU consumer standards.”
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