On December 6, 2021, the State Administration for Market Regulation issued a circular to seek public comments on a draft of the Measures for Determination of Illegal Gains in Administrative Penalty Cases by Administrations for Market Regulation (Draft for Comment) (the "Draft Measures"), which is open for public comment until January 5, 2022. The Draft Measures are intended to support the recently revised Law of the People's Republic of China on Administrative Penalty (the "Administrative Penalty Law"), which took effect on July 15, 2021, and would replace the existing Measures for Determination of Illegal Gains in Administrative Penalty Cases by Administrative Organs for Industry and Commerce ("Decree 37"). The Draft Measures aim to resolve the problem of inconsistent criteria for determining illegal gains in administrative law enforcement practice.