China mobile smart terminal preinstallation and distribution duties for device makers and app distribution workflows.
Apply the 2017 manufacturer and app-distributor rules together with the stricter preinstallation notice effective 1 January 2023.
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Cited legal and guidance references.
A is a mobile communication terminal that connects to a public mobile network, has an operating system and lets users install and uninstall apps. Smartphones, tablets and qualifying wearables are representative examples; industrial terminals, special-purpose in-vehicle terminals and products that do not connect to a public mobile network fall outside the 2022 notice's explained terminal scope. The 2017 interim provisions regulate terminal manufacturers and app-distribution service providers. For manufacturer-preinstalled programs with a user-interaction entry on the main or auxiliary screen that can operate independently, also apply the 2022 MIIT-CAC notice effective 1 January 2023.
The 2017 provisions set the disclosure, consent, charging, channel and distribution controls. The 2022 notice supplements those provisions rather than replacing them: it narrows the removability exception, makes the company that preinstalls an app responsible for it, and requires manufacturers to prevent operating-system replacement and unauthorized app installation during product distribution. Apply the duties by role: a terminal manufacturer owns the factory image and channel controls, an app provider owns its app conduct and disclosures, a distribution platform owns review and traceability, and a billing provider owns billing confirmation records.
All preinstalled apps outside the current must have a safe and convenient uninstall method. Under the 2017 provisions, associated resource, configuration and user-data files must also be conveniently removable when that does not affect safe terminal use.
App stores and manufacturers that preinstall distribution platforms have additional traceability duties.
The interim provisions took effect on 1 July 2017, and the supplemental MIIT-CAC preinstallation notice took effect on 1 January 2023. MIIT and provincial communications administrations supervise the 2017 duties; MIIT and CAC jointly supervise the 2022 preinstallation controls. Authorities can require correction or app removal, and administrative penalties under the applicable law may be recorded and published.
Connect the applicable China route, cited source, accountable owner, approval, product configuration and change history in one reviewable model file.
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Review unresolved equipment classification, approval, transition or product-change questions before release.