In May 2023, the State Administration for Market Regulation and 11 other departments jointly issued the "Guiding Opinions on Further Strengthening the Supervision of the Medical Beauty Industry", which clearly stated that the handling of "medical care" and "medication" should be strengthened in accordance with the law, and the illegal conduct of diagnosis and treatment consultation and medical guidance should be severely cracked down on. The interviewed experts pointed out that both medical beauty "Meituo" and traditional "medical entrusted" essentially exploit information asymmetry and the urgent psychology of consumers (or patients) to fraudulently attract traffic to specific institutions and seek illegitimate benefits from them. Both have commonalities in their core behavioral patterns, which are mainly based on "false advertising" and "inducing consumption". However, there are significant differences between the two in terms of behavioral characteristics, scope of harm, and operational modes. Zheng Zhongchen, director of Beijing Lutong Law Firm, introduced that compared to traditional "medical care", the behavior of medical beauty "beauty care" presents a more obvious chain of operation mode. Medical beauty "Meituo" usually relies on the interest chain composed of "channel based medical beauty institutions - intermediaries/agents - beauty salons and other terminal places -" Meituo "personnel". The tight binding of various links through high profit sharing forms a stable community of interests, enhancing the concealment of their behavior and the difficulty of investigation and evidence collection. He also mentioned that such behavior is often implemented through carefully designed "scripted" scenarios, in specific environments such as beauty salons and social occasions, where roles such as "beauty technicians," "old customers," "VIP customers," and "face therapists" work together to mislead consumers with "immersive" language and performance, which is more deceptive and difficult for ordinary consumers to identify and prevent. Zheng Zhongchen said that medical beauty "Meituo" not only disrupts market order and endangers consumers' health rights, but also infringes on consumers' rights to information, fair trade, and property. It often accompanies behaviors such as inducing consumers to apply for online loans, which to some extent adds financial risks. In addition, the medical beauty projects it promotes may have problems such as incomplete qualifications, false effects, and non-standard operations, which can easily cause irreversible damage to consumers' physical and mental health. Deng Liqiang, Executive Director of the China Health Law Association, stated that from a legal perspective, the behavior of medical beauty "Meituo" is suspected of multiple illegal and irregular activities, including violating the Civil Code and the Consumer Rights Protection Law, constituting fraudulent consumption, and disrupting the fair competition order in the medical beauty market. However, consumers face many difficulties in protecting their rights when encountering problems. Zheng Zhongchen pointed out that the "Meituo" behavior may also be suspected of violating advertising laws, and in serious cases, may even constitute fraud. It should be noted that "Meituo" and the cooperating beauty salon technicians are the direct responsible persons. Channel medical beauty institutions and their interviewers are the ultimate implementers and biggest beneficiaries of fraud. In addition to bearing the responsibility for fraud, the "channel rebate" included in their inflated quotations is the key evidence for determining commercial bribery (bribery). In Zheng Zhongchen's view, there is a certain difficulty in cracking down on such illegal activities. One is the difficulty of obtaining evidence. The 'language technique' is mostly verbal communication, leaving no trace. Contracts and consent forms signed by consumers under the influence of "atmosphere" may appear "legal" in form and are difficult to directly identify as fraud. The funding chain is concealed, and channel fees and rebates are usually circulated through personal accounts, cash, or complex accounts, disguised as "consulting fees", "promotion fees", etc., making it difficult to verify their bribery nature. The determination of subjective intent is difficult, and it is difficult to prove the subjective intent of "conspiracy fraud" among the participants in each link. The threshold for legal recognition is relatively high. The second is the difficulty of qualitative analysis. Illegal activities span across multiple fields such as market regulation (false advertising, price fraud), health and hygiene (illegal diagnosis and treatment, practicing beyond the scope), financial regulation (inducing online lending), and cross departmental responsibilities, making it difficult to characterize behavior. The third is the difficulty of governance. The cost of illegal activities is low and the benefits are high. Even if a certain link is investigated and dealt with, the parties involved can still change their appearance and return to their old business. However, consumer rights protection is time-consuming and labor-intensive, with a low percentage of successful lawsuits and compensation, making it difficult to form an effective deterrent. ”Zheng Zhongchen said. Therefore, Zheng Zhongchen suggested that in order to crack down on the "murder mystery" of medical aesthetics, it is necessary to break away from the "case by case punishment" thinking and establish a governance system of "source prevention, strict process management, chain strike, and joint punishment". He believes that it is necessary to strengthen the main responsibility of institutions. Strictly control the channel mode, and health departments and market supervision departments should regard "high channel rebates" (such as exceeding 30%) as a key monitoring indicator for commercial bribery and price violations. Require medical beauty institutions to publicize their cooperation channels and conduct targeted audits and inspections on institutions with abnormal proportions of channel fees. Promote transparent pricing, mandate that all medical beauty projects prominently display project details, prices, physician qualifications, and potential medical risks in store, and explore the implementation of a "surgical project and price filing system". Standardize advertising and consulting, strictly implement the Advertising Law and the Medical Advertising Management Measures. The attending physician must be a compliant physician, and their consultation opinions should be recorded and traceable. Deng Liqiang believes that the medical beauty "Meituo" industry chain has strong concealment and can be coordinated by multiple departments such as pricing, market supervision, and taxation. The focus should be on conducting precise investigations and strengthening governance efforts against medical beauty institutions that have the "Meituo" phenomenon. Build a cross departmental collaborative law enforcement mechanism. Establish a special governance linkage mechanism, led by the market supervision department and involving relevant departments, to achieve interconnection of clues, case sharing, and law enforcement linkage. ”Zheng Zhongchen said. In Zheng Zhongchen's view, it is also necessary to open up channels for consumer rights protection and increase the illegal costs of relevant institutions. Implementing the reversal of the burden of proof, when consumers report or sue medical beauty institutions suspected of fraud, the institutions shall self verify the authenticity of their advertising, the reasonableness of their prices, and the compliance of their operations. Implement joint punishment, not only impose administrative penalties on the verified illegal institutions and responsible persons, but also include them in the credit system, restrict financing, high consumption, industry access and other aspects, so that they can be "restricted everywhere for one violation". Strengthen public education, enhance prevention awareness, and popularize rational medical aesthetics concepts. Through authoritative media and platforms, consumers are repeatedly reminded to be cautious when recommending "acquaintances", that "perfect cases" may be "scripts", and that "limited time discounts" are often traps. (New Society)