Practicalities

Prepaid Cards in China

Five pages on this site tell you to refuse the prepaid membership card, one of them calling it the most-complained-about practice in the industry, and none of them says why or what happens if you already said yes. All three answers changed in the last two years, and the direction of travel is entirely towards the customer.

The instruction
Decline the card — still right
The reason
The shop closing, not the upsell
Since 1 July 2024
A written contract is required
Since 1 May 2025
Seven days to demand the principal
"No refunds" signs
Void, not binding

Walk into a Chinese foot-massage shop, hairdresser or gym and you will, at some point in the hour, be offered a card. Pay ten sessions up front, get twelve. Pay two thousand yuan, get two thousand four hundred of credit. It is the standard commercial model of an entire tier of the Chinese service economy.

This site has told you five separate times to say no — in the massage guide and on four city pages, one of which calls it the most-complained-about practice in the industry. That advice is correct and it is not changing here.

What is missing is everything else: why the practice is complained about, what the card actually is in law, and what happens if you already handed over the money. That last one is the interesting part, because the honest answer stopped being "nothing" on 1 May 2025.

What the risk actually is#

The problem with a Chinese prepaid card has never really been the upsell. It is that you are an unsecured creditor of a small business.

You pay now for services delivered over months. If the shop closes, changes hands or quietly disappears between one visit and the next — which happens often enough to have its own everyday expression, 卷款跑路 (juǎnkuǎn pǎolù, rolling up the cash and running) — your balance goes with it. For a resident that is an annoyance and a court case. For a visitor with a flight booked it is simply a loss.

That is the real reason to decline, and it is a better reason than "you are not coming back next month".

The floor: a written contract, since July 2024#

The first layer is the 中华人民共和国消费者权益保护法实施条例 (Zhōnghuá Rénmín Gònghéguó Xiāofèizhě Quányì Bǎohùfǎ Shíshī Tiáolì, Regulations for the Implementation of the Consumer Rights Protection Law), State Council Order No. 778, adopted at the 26th executive meeting on 23 February 2024 and in force since 1 July 2024.

Its Article 22 is the prepaid provision, and it does four things:

  • An operator taking prepayment must conclude a written contract with the consumer, setting out the goods or services, the price, the method of refunding the prepayment, and liability for breach.
  • Having taken the money it must deliver as agreed, may not reduce quality and may not arbitrarily raise the price. If it does not deliver as agreed, it must perform or refund the prepayment at the consumer's demand.
  • An operator facing major operating risk that might affect normal delivery must stop taking prepayments.
  • An operator deciding to close or relocate must tell consumers in advance, and the consumer may demand continued performance or the refund of the unconsumed balance.

Article 21 puts a number on that notice: an operator closing or moving premises must give thirty days' advance public notice, in a conspicuous position at the premises and on its website or online-shop homepage, including valid contact details.

So the card is not a gift voucher whose terms the shop writes alone. It is a contract with a statutory floor under it.

The ceiling: seven days, since May 2025#

The second layer is the one nobody outside China has written about, and it is the reason this page exists.

The 最高人民法院关于审理预付式消费民事纠纷案件适用法律若干问题的解释 (Zuìgāo Rénmín Fǎyuàn guānyú Shěnlǐ Yùfù Shì Xiāofèi Mínshì Jiūfēn Ànjiàn Shìyòng Fǎlǜ Ruògān Wèntí de Jiěshì, Interpretation on Questions of Applicable Law in Adjudicating Civil Disputes over Prepaid Consumption) is 法释〔2025〕4号 (fǎ shì, judicial interpretation no. 4 of 2025). It was adopted by the Supreme People's Court adjudication committee at its 1,932nd session on 18 November 2024 and has been in force since 1 May 2025.

Its Article 1 sets the scope by naming the trades, and the list reads like the index of this site: retail, accommodation, catering, fitness, transport, hairdressing, beauty, training, elderly care and tourism.

Then Article 14:

消费者自付款之日起七日内请求经营者返还预付款本金的,人民法院应予支持。

Where a consumer asks the operator to return the principal of the prepayment within seven days of the date of payment, the people's court shall support it.

A seven-day cooling-off period on a prepaid card, in other words, created by the court that hears the disputes.

The sign behind the counter is not law#

Article 9 is the provision that quietly repeals a great deal of Chinese shop signage. It lets a consumer have standard-form clauses declared void, including clauses that:

  • exclude the consumer's right to terminate the contract or to demand a refund;
  • unreasonably restrict the right to transfer the contract to someone else;
  • provide that a lost registered card will not be replaced;
  • let the operator unilaterally change the substance of the contract;
  • exclude liability for defects or for damages;
  • impose a dispute procedure that unreasonably raises the cost of enforcing your rights.

"Non-refundable, non-transferable, lost cards not replaced, the shop reserves final interpretation" is the standard set of words on a Chinese membership card. Under Article 9 those words are not a term you agreed to. They are a term a court can strike out.

And Article 23 deals with the disappearance itself: an operator that stops trading after taking prepayments, neither delivers nor refunds, and maliciously evades refund requests, amounting to fraud, bears punitive damages under the Consumer Rights Protection Law — with criminal leads referred to the police.

Checked for newer, and Shanghai has one#

At the national level nothing has superseded the 2025 interpretation. Locally, something has.

The 上海市单用途预付消费卡管理规定 (Shànghǎi Shì Dān Yòngtú Yùfù Xiāofèi Kǎ Guǎnlǐ Guīdìng, Shanghai Municipal Provisions on the Administration of Single-Purpose Prepaid Consumption Cards) was revised by the Standing Committee of the Shanghai Municipal People's Congress on 26 November 2025 and has been in force since 1 January 2026. It is a municipal regulation, so it binds in Shanghai and nowhere else.

Its Articles 16 and 17 attack the problem at the root rather than after the loss: operators inside the filing system must hold prepaid funds through commercial bank custody, a digital renminbi wallet, a service trust or notarial escrow, and those using bank custody must open a dedicated deposit account for the money. The point is that the balance stops being the shop's working capital.

I looked for a seven-day refund right in the Shanghai text and did not find one. The seven days come from the national interpretation, which applies in Shanghai anyway.

What this is worth to a visitor, honestly#

All of the above is real, and almost none of it is a plan for a two-week trip.

Enforcing Article 14 means a Chinese court. Article 9 makes a clause void, but somebody has to raise it. Punitive damages under Article 23 arrive at the end of a process no tourist is going to start from another continent. The realistic remedy is 12315, the market regulator's consumer line, which already appears on this site as the number behind overcharging disputes and is where a refund refusal actually goes.

So the practical value of knowing this is narrower than the law, and still worth having:

  • The pressure sale has an answer. You are not obliged to decide in the chair, and for seven days after paying you are not stuck with the decision either.
  • "No refunds" is not the end of the conversation. It is a clause a court can void, which changes the tone of asking.
  • A card is a debt the shop owes you, not a purchase you completed, and it is worth exactly as much as the shop's next twelve months.

In practice#

  • Still decline the card. Nothing here changes that; it improves the reason.
  • Pay for the single session. In massage and foot treatment the per-visit price is low enough that the discount is not worth the exposure.
  • If you did pay, act inside seven days. That is the window in which the law is simple.
  • Photograph the contract and the receipt. A written contract is required, and the refund method has to be in it.
  • Keep it on a card you can dispute where possible — the wallets and what they will and will not do is the separate practical layer.
  • 12315 is the realistic route, not a courtroom.

Frequently asked questions#

Can I get a refund on a prepaid card in China?#

Often yes. Since 1 May 2025 a Supreme People's Court interpretation requires courts to support a consumer who asks for the principal back within seven days of paying, unless they had already obtained the same goods or services from that operator or another one. Separately, if the business closes or moves, the consumer may demand the unconsumed balance back.

No. The 2025 interpretation lets a consumer have such clauses declared void, along with clauses barring transfer of the card, refusing to replace a lost registered card, allowing the operator to change the contract unilaterally, or excluding liability. The wording printed on the card is not automatically a term you are bound by.

Should tourists buy prepaid cards in China?#

No. The discount is real but so is the exposure: you are paying now for services delivered over months, in a business you will never revisit. Pay per session. The legal protections described here exist, but using them means a Chinese complaint process or court.

What happens if a Chinese shop closes with my card balance?#

The implementing regulations require thirty days' advance public notice of closure or relocation and allow you to demand the unconsumed balance. If the operator stops trading, refuses to deliver and maliciously evades refunds, the interpretation provides for punitive damages and referral of criminal leads to the police.

Does China require a contract for prepaid purchases?#

Yes. Since 1 July 2024, State Council Order No. 778 requires an operator taking prepayment to conclude a written contract covering the goods or services, the price, the method of refunding the prepayment and liability for breach — and to stop taking prepayments if it faces major operating risk.

Who do I complain to about a prepaid card in China?#

12315, the market regulator's consumer hotline. It is the same line that handles overcharging and marked-price disputes, and it is the realistic route for a visitor, since the court remedies in the judicial interpretation assume a claimant who can attend a Chinese court.