The rapid development of e-commerce in Southeast Asia,
particularly in Indonesia and Singapore, has opened up new
economic opportunities, but it has also raised serious concerns
regarding the circulation of counterfeit products on digital
marketplace platforms. Counterfeit products not only harm the
original manufacturer economically, but also endanger
consumers in terms of health and safety. This research aims to
evaluate and compare the legal responsibility of marketplaces
for consumer losses due to counterfeit products based on
regulations in Indonesia and Singapore. The method employed
was a normative, juridical, and macro-comparative approach,
involving the analysis of laws and regulations, legal doctrines,
and interviews with stakeholders in the consumer protection
sector. The results indicate that Indonesia lacks a robust legal
framework for holding marketplaces accountable, which
hinders consumers' access to effective legal protection. In
contrast, Singapore has developed a progressive legal system
through the Consumer Protection (Fair Trading) Act, which
requires marketplaces to apply the precautionary principle and
provide efficient dispute resolution mechanisms. The findings
confirm that marketplaces should be positioned as active
business actors who can be held legally liable when harm occurs
to consumers due to the sale of counterfeit products. This
research recommends revisions to Indonesia's Consumer
Protection Law and Government Regulation No. 80/2019 to
align with the development of modern e-commerce practices,
including the implementation of digital product certification and
reverse proof to ensure fairness for consumers.