Export compliance: China to the EU and the United States
What a Chinese exporter meets on the way out and on the way in: 12 Chinese rules read against the EU and US registers, in one place.
- The route out of China is decided by the item and the data: a control list, a transfer route for personal data, an origin rule and, for listed goods, a certification step.
- The route into the EU or the United States is decided by the receiving register; this page points at the rule, it never states that a shipment is cleared.
- Supervised by NPCSC, State Council, CAC, MOFCOM, GACC, SAMR and MIIT. Published by National People's Congress, Cyberspace Administration of China, State Council, General Administration of Customs and State Administration for Market Regulation.
What the direction of trade decides
Personal data
- Personal Information Protection Law of the People's Republic of China — PIPL, adopted by the NPCSC on 20 August 2021. The law applies since 1 November 2021 and covers processing outside China aimed at people inside China.
- Cybersecurity Law of the People's Republic of China — Cybersecurity Law, adopted 7 November 2016. The law applies since 1 June 2017 and is the base text for network operator duties.
- Data Security Law of the People's Republic of China — Data Security Law, adopted 10 June 2021. The law applies since 1 September 2021 and covers data of every kind, not only personal data.
- Measures on the Standard Contract for Outbound Transfer of Personal Information — CAC Order No. 13 of 2023. The measures apply since 1 June 2023 and set a fixed contract text that is filed with the authority.
Cross-border data transfer
- Personal Information Protection Law of the People's Republic of China — PIPL, adopted by the NPCSC on 20 August 2021. The law applies since 1 November 2021 and covers processing outside China aimed at people inside China.
- Data Security Law of the People's Republic of China — Data Security Law, adopted 10 June 2021. The law applies since 1 September 2021 and covers data of every kind, not only personal data.
- Measures for the Security Assessment of Outbound Data Transfers — CAC Order No. 11 of 2022. The measures apply since 1 September 2022 and set the thresholds that trigger a state security assessment.
- Measures on the Standard Contract for Outbound Transfer of Personal Information — CAC Order No. 13 of 2023. The measures apply since 1 June 2023 and set a fixed contract text that is filed with the authority.
- Provisions on Facilitating and Regulating Cross-border Data Flows — CAC Order No. 16 of 2024. The provisions apply from the day they were issued and name exemptions from the earlier transfer steps.
Export control
- Export Control Law of the People's Republic of China — Export Control Law, adopted 17 October 2020. The law applies since 1 December 2020 and is the base text for controlled items and end-user checks.
- Regulations on Export Control of Dual-Use Items — State Council Order No. 792. The regulations apply since 1 December 2024 and gather the dual-use licensing rules in one text.
Product requirements
- Regulations on Compulsory Product Certification (CCC) — Compulsory product certification, CCC mark. The scheme applies to products on the published catalogue; the catalogue is updated by the authority.
AI governance
- Interim Measures for the Management of Generative AI Services — Interim Measures, issued 10 July 2023. The measures apply since 15 August 2023 to generative services offered to the public inside China.
- Provisions on the Management of Algorithmic Recommendation in Internet Information Services — CAC Order No. 9 of 2021. The provisions apply since 1 March 2022 and require a public register entry for the algorithm.
Customs and origin
- Regulations on the Origin of Import and Export Goods — State Council Order No. 416. The regulations apply since 1 January 2005 and decide which country counts as the origin of the goods.
Official sources
- 中华人民共和国个人信息保护法 — National People's Congress
- 中华人民共和国网络安全法 — National People's Congress
- 中华人民共和国数据安全法 — National People's Congress
- 数据出境安全评估办法 — Cyberspace Administration of China
- 个人信息出境标准合同办法 — Cyberspace Administration of China
- 促进和规范数据跨境流动规定 — Cyberspace Administration of China
- 中华人民共和国出口管制法 — National People's Congress
- 中华人民共和国两用物项出口管制条例（国务院令第792号） — State Council
- 中华人民共和国进出口货物原产地条例（国务院令第416号） — State Council
- 中华人民共和国海关进出口货物申报管理规定 — General Administration of Customs
- 强制性产品认证管理规定 — State Administration for Market Regulation
- 生成式人工智能服务管理暂行办法 — Cyberspace Administration of China
- 互联网信息服务算法推荐管理规定 — Cyberspace Administration of China
The register states what the official texts say. It is not advice and it is not a verdict on any company.
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