← Cases
ChinaConsumer goods2020–2021

Kohler China

Facial recognition for store traffic measurement

Kohler removed facial-recognition equipment from 222 Chinese stores and received a CNY 500,000 fine

StoppedRegulator, audit or court

Problem

Kohler wanted more accurate store traffic counts to support sales planning. The system removed staff and repeat visitors from the count by comparing facial information.

Approach

Following a February 2020 contract, Wandianzhang installed cameras in Kohler's dealer stores and processed facial images on cloud servers. Shanghai's Jing'an market regulator found that Kohler had collected facial information without consumers' consent. After CCTV reported the practice in March 2021, Kohler apologized, the stores removed the equipment, and the vendor deleted the associated data. The regulator imposed a CNY 500,000 fine in July 2021 and recorded that the information had been used for traffic counting rather than sold.

Results

CNY 500,000administrative fineRegulator, audit or court[1]
222stores from which the equipment was removedRegulator, audit or court[1]
2,202,264facial-information records collected, not a count of unique peopleRegulator, audit or court[1]

Takeaway

The purpose was routine traffic measurement, but the method required collecting customers' facial information. The regulator found that this collection needed consent even though Kohler had not sold the information.

Categories

Innovation type
Process innovation
AI technology
Computer vision
Evidence
Regulator, audit or court

Sources

  1. 上海市静安区市场监督管理局行政处罚决定书
    Shanghai Jing'an District Administration for Market Regulation, reproduced by CESI26 Jul 2021Regulator, audit or court document
  2. 科勒被罚50万元,曾违规抓取220万条人脸信息
    Leju Finance, republished by Sohu6 Aug 2021News article

Source summaries

[1]Shanghai Jing'an District Administration for Market Regulation, reproduced by CESI26 Jul 2021

The reproduced decision documented the contract, processing method and lack of consent. It recorded 2,202,264 facial-information records, removal of equipment from 222 stores on March 15 and 16, deletion of the data, and a CNY 500,000 fine.

[2]Leju Finance, republished by Sohu6 Aug 2021

The report described collection between February 2020 and March 2021 and the regulator's fine. It reported that Kohler apologized after CCTV's coverage and arranged overnight removal of the equipment.

Full details are in the original sources.

Added 4 Nov 2026 · Updated 4 Nov 2026
Open case page ↗