CHINA
Reported in 2014, last reported in 2025
Pillar Online sales and transactions |
Indicator Restrictions on online payments
Reported licensing barriers
It is reported that challenges persist in relation to the licensing process for foreign suppliers of electronic payment services in China, where, prior to June 2017, foreign providers were not permitted to apply for licences until the central bank formalised a two-stage licensing framework. As of 2020, no foreign supplier had successfully obtained the licence required to operate in the Chinese market, largely due to procedural delays attributable to the central bank, although that same year American Express became the first foreign provider to secure such a licence, followed by Mastercard in November 2023 after prolonged delays, while the central bank has continued to defer action on the application submitted by Visa for an even longer period, and additional difficulties have been reported in relation to licensing requirements for non-bank providers of online payment services, thereby reinforcing existing barriers to entry into the Chinese market.
Coverage Payment services
CHINA
Reported in 2021, last reported in 2025
Pillar Online sales and transactions |
Indicator Threshold for ‘De Minimis’ rule
Limited de minimis threshold
According to Art. 45 of the Regulations of the People's Republic of China on Import and Export Duties (中华人民共和国进出口关税条例), goods within a single consignment, for which the estimated duties do not exceed 50 Yuan (approx. USD 7.5) shall be exempt from duties. In addition, it is reported that China Customs also applies a dedicated e-commerce clearance channel with a goods value de minimis of 5,000 RMB (approx. 700 USD), subject to meeting certain conditions, such as prior carrier and platform registration. Use of this channel is limited to an annual cap of RMB 26,000 (approx. USD 3,600).
Coverage Horizontal
Sources
- https://web.archive.org/web/20260312193010/https://global-express.org/index.php?id=271&act=101&profile_id=-1&countries%5B%5D=-2&search_terms=&question-filter=&qid_34=1&qid_34_optid=1&qid_35=1&qid_36=1...
- https://web.archive.org/web/20240224235121/https://mag.wcoomd.org/magazine/wco-news-84/cross-border-e-commerce-in-china/
- https://web.archive.org/web/20221208154052/https://www.gov.cn/gongbao/content/2017/content_5219152.htm
- https://web.archive.org/web/20230227012953/https://global-express.org/assets/files/GEA%20De%20Minimis%20Country%20information_4%20November%202021.pdf
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CHINA
Since August 2021, entry into force in November 2021
Pillar Online sales and transactions |
Indicator Local presence requirements for digital services providers
Personal Information Protection Law of the People's Republic of China (中华人民共和国个人信息保护法)
According to Art. 53 of the Personal Information Protection Law, personal information processors outside the territory of the People's Republic of China, as specified in Art. 3, shall set up specialised agencies or designate representatives within the territory of the People's Republic of China to be responsible for handling personal information protection related matters, and shall submit the names, contact information, and other information of the agencies and representatives to the departments with personal information protection duties.
Coverage Horizontal
CHINA
Since June 2017
Since June 2017
Since June 2017
Pillar Online sales and transactions |
Indicator Local presence requirements for digital services providers
Internet News Information Service Management Regulations (互联网新闻信息服务管理规定)
Provisions on Administrative Law Enforcement Procedures for Internet Information Content Management (互联网信息内容管理行政执法程序规定)
Provisions on Administrative Law Enforcement Procedures for Internet Information Content Management (互联网信息内容管理行政执法程序规定)
According to Art. 5 of the Internet News Information Service Management Regulations, Internet news providers are required to obtain a permit to provide Internet news information services to the social public through Internet websites, application software, forums, blogs, microblogs, public accounts, instant messaging tools, online live streaming, and other such methods. Pursuant to Art. 6 of the regulations, the applicant’s person-in-charge or chief editor must be a Chinese citizen. In addition, the applicant must separately obtain an Internet Information Service license or file procedures with the telecommunications authorities in accordance with the law. In addition, according to Art. 6, to apply for an Internet news information service license, one must have places, facilities, and funds suitable for the service. The Regulations on Administrative Enforcement Procedures for Internet Information Content set out the procedural and administrative processes for the Cyberspace Administration of China to enforce the laws and regulations relating to Internet content.
These provisions broadened the definition of “internet news information services” to “services of collecting, editing, and releasing internet news information; reposting such news information; and providing a platform to spread such news information.” They also broaden the definition of “news information” to include relevant reports and commentaries on politics, the economy, military affairs, foreign affairs, and other public affairs, as well as relevant reports and commentaries on social emergencies.
These provisions broadened the definition of “internet news information services” to “services of collecting, editing, and releasing internet news information; reposting such news information; and providing a platform to spread such news information.” They also broaden the definition of “news information” to include relevant reports and commentaries on politics, the economy, military affairs, foreign affairs, and other public affairs, as well as relevant reports and commentaries on social emergencies.
Coverage News providers
Sources
- https://web.archive.org/web/20231107150741/http://www.cac.gov.cn/2017-05/02/c_1120902760.htm
- https://web.archive.org/web/20231107150746/http://www.cac.gov.cn/2017-05/02/c_1120902931.htm
- https://web.archive.org/web/20211025231346/https://www.lexology.com/library/detail.aspx?g=af1b1b36-3c2c-45ef-b328-9566de509b33
- https://web.archive.org/web/20220127231019/https://www.lexology.com/library/detail.aspx?g=b2aa77aa-0270-40f8-9f18-ad65b6130259
- https://web.archive.org/web/20231221221634/https://chinacopyrightandmedia.wordpress.com/2017/05/02/internet-news-information-service-management-regulations-2/
- https://web.archive.org/web/20230917093303/http://finance.sina.com.cn/roll/2017-05-04/doc-ifyexxhw2298844.shtml
- https://web.archive.org/web/20231030123540/https://www.reuters.com/article/us-china-internet-censorship-security-idUSKBN17Y0Y6
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CHINA
Since October 1993, entry into force in January 1994, last amended in March 2014
Since August 2018, last amended in January 2019
Since August 2018, last amended in January 2019
Pillar Online sales and transactions |
Indicator Framework for consumer protection applicable to online commerce
Consumer Rights and Interests Protection Law of the People's Republic of China (中华人民共和国消费者权益保护法)
E-Commerce Law of the People’s Republic of China (中华人民共和国电子商务法)
E-Commerce Law of the People’s Republic of China (中华人民共和国电子商务法)
The Consumer Rights and Interests Protection Law and the E-Commerce Law provide a comprehensive framework for consumer protection that also applies to online transactions.
Coverage Horizontal
Sources
- https://web.archive.org/web/20250827153428/https://amr.sz.gov.cn/xxgk/zcwj/scjgfg/xfzqy/12315fl/content/post_1995131.html
- https://web.archive.org/web/20260317202641/https://www.12371.cn/2020/06/11/ARTI1591822932213296.shtml
- https://unctad.org/page/cyberlaw-tracker-country-detail?country=cn
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CHINA
N/A
Pillar Online sales and transactions |
Indicator Ratification of the UN Convention on the Use of Electronic Communications in International Contracts
Lack of ratification of the UN Convention on the Use of Electronic Communications in International Contracts
China has signed but not ratified the United Nations (UN) Convention on the Use of Electronic Communications in International Contracts.
Coverage Horizontal
CHINA
Since 2004
Pillar Online sales and transactions |
Indicator UNCITRAL Model Law on Electronic Commerce
UNCITRAL Model Law on Electronic Commerce
China has adopted national legislation based on or influenced by the United Nations Commission on International Trade Law (UNCITRAL) Model Law on Electronic Commerce.
Coverage Horizontal
CHINA
Since August 2004, entry into force in April 2005
Pillar Online sales and transactions |
Indicator UNCITRAL Model Law on Electronic Signatures
Electronic Signature Law of the People's Republic of China (中华人民共和国电子签名法)
China has adopted national legislation based on the United Nations Commission on International Trade Law (UNCITRAL) Model Law on Electronic Signatures, namely the Electronic Signature Law.
Coverage Horizontal
CHINA
Reported in 2025
Pillar Quantitative trade restrictions for ICT goods and online services |
Indicator Export restrictions on ICT goods or online services
Reported restrictions on critical material exports
It is reported that, citing national security considerations, China introduced two successive rounds of export controls on rare‑earth elements in April and October 2025, with the implementation of the second round suspended until November 2026. On 4 April 2025, China imposed export controls on seven heavy rare‑earth elements subject to licensing requirements, together with all related compounds, metals and magnets, and exporters are required to obtain a licence and disclose information regarding end users, which some firms view as commercially sensitive and which many exporters consider to be handled through an intentionally opaque, selective and slow process. A second wave of restrictions on 9 October 2025 extended the controls to a further five rare‑earth elements, associated products, equipment, technologies and specialist personnel expertise, thereby broadening the regime beyond physical goods to encompass technological know‑how and foreign‑made products incorporating Chinese inputs. Under these expanded rules, foreign firms would be required to obtain authorisation to export magnets containing even trace quantities (0.1%) of Chinese‑sourced rare‑earth elements or magnets manufactured using Chinese mining, processing or magnet‑making technologies.
Coverage Rare-earth elements
CHINA
Reported in 2020, last reported in 2025
Pillar Technical standards applied to ICT goods and online services |
Indicator Open and transparent standard-setting process
Lack of foreign participation in standard-setting
It is reported that the Chinese Government is working to improve its standards system by incorporating both government guidance and market input, moving away from a solely government-led approach. Despite this progress, foreign participation in standards setting remains limited, and China often pursues unique national standards for strategic reasons. The revised standardisation Law, effective since January 2018, includes measures recognising the value of international standards and the participation of foreign-invested enterprises. However, foreign stakeholders are concerned that these measures still prioritise Chinese standards over international ones and do not ensure equal participation for foreign companies. Reports indicate that foreign companies often face restrictions in participating in China's domestic standards-setting processes, and even when participation is allowed, it is usually under less favourable terms than for domestic competitors.
Coverage Horizontal
CHINA
Since January 1996
Since June 2001
Since August 2003
Since June 2001
Since August 2003
Pillar Technical standards applied to ICT goods and online services |
Indicator Self-certification for product safety
State Radio Regulation of China (SRRC) (无线电设备型号核)
Network Access License (NAL) (进网许可证)
China Compulsory Certification (CCC) Requirement (中国强制认证(CCC)要求)
Network Access License (NAL) (进网许可证)
China Compulsory Certification (CCC) Requirement (中国强制认证(CCC)要求)
China’s current certification requirements for telecommunications equipment are reported to conflict with its WTO obligations of limiting imported products to no more than one conformity assessment scheme and requiring the same mark for all products (Article 13.4.a of China’s WTO Accession).
China has three different licensing regimes: the State Radio Regulation of China (SRRC), the Network Access License (NAL) and the China Compulsory Certification (CCC). The CCC is required for a list of products that includes many types of IT products, such as video and audio equipment. The NAL is required for all telecommunications equipment in China. The NAL license requires extensive testing and support and may include network trials and review of the product by a local panel of experts, in addition to labouratory testing against China's national standards. Radio communication equipment intended to be marketed in China requires radio-type approval granted by the Ministry of Industry and Information Technology of the People’s Republic of China (MIIT)’s ‘State Radio Regulation Committee (SRRC). Specified equipment samples are tested in designated labouratories according to local Chinese standards.
Therefore, for a given piece of equipment, it can cost between USD 30,000-35,000 to test for all three licenses (SRRC, NAL, and CCC). The CCC mark is used for both Chinese and foreign products. Moreover, all testing for the CCC mark must be conducted in China, and US exporters are often required to submit their products to Chinese labouratories for additional tests.
The CCC certificate and permission to print the CCC mark must be renewed annually as part of a follow-up certification. Part of the follow-up certification is also a one-day factory audit.
China is also reported as having limitations on foreign -invested conformity assessment bodies in the country.
China has three different licensing regimes: the State Radio Regulation of China (SRRC), the Network Access License (NAL) and the China Compulsory Certification (CCC). The CCC is required for a list of products that includes many types of IT products, such as video and audio equipment. The NAL is required for all telecommunications equipment in China. The NAL license requires extensive testing and support and may include network trials and review of the product by a local panel of experts, in addition to labouratory testing against China's national standards. Radio communication equipment intended to be marketed in China requires radio-type approval granted by the Ministry of Industry and Information Technology of the People’s Republic of China (MIIT)’s ‘State Radio Regulation Committee (SRRC). Specified equipment samples are tested in designated labouratories according to local Chinese standards.
Therefore, for a given piece of equipment, it can cost between USD 30,000-35,000 to test for all three licenses (SRRC, NAL, and CCC). The CCC mark is used for both Chinese and foreign products. Moreover, all testing for the CCC mark must be conducted in China, and US exporters are often required to submit their products to Chinese labouratories for additional tests.
The CCC certificate and permission to print the CCC mark must be renewed annually as part of a follow-up certification. Part of the follow-up certification is also a one-day factory audit.
China is also reported as having limitations on foreign -invested conformity assessment bodies in the country.
Coverage Electrical and ICT goods
Sources
- https://web.archive.org/web/20170610214814/http://www.tiaonline.org/gov_affairs/fcc_filings/documents/P%20Telecommunications%20Industry%20Association%201377%20Report.pdf
- https://web.archive.org/web/20170826034140/http://www.china-certification.com/en/network-access-license-nal-for-telecommunication-equipment
- https://web.archive.org/web/20230929193647/http://www.china-certification.com/en/list-of-ccc-mandatory-products/
- https://web.archive.org/web/20200805072748/http://www.cnca.gov.cn:80/cnca/cncatest/20040420/column/227.htm
- https://web.archive.org/web/20230324181523/https://www.typeapproval.com/china/#telecommunications-equipment
- https://web.archive.org/web/20241202144202/https://www.tuv.com/market-access-services/en/certification-filter/srrc-approval.html
- https://web.archive.org/web/20220304051816/http://www.gov.cn/flfg/2009-07/21/content_1369826.htm
- http://www.lcs-rf.com/readnews.asp?id=158
- https://web.archive.org/web/20230302164952/http://www.tinglitu.com/html/200305/law_97539.html
- https://www.appluslaboratories.com/global/es/what-we-do/service-sheet/china-radio-type-approval-
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CHINA
Since June 2007
Since December 2019
Since December 2019
Since December 2019
Since December 2019
Since December 2019
Since December 2019
Pillar Technical standards applied to ICT goods and online services |
Indicator Self-certification for product safety
Administrative Measures for the Multi-level Protection of Information Security
Information Security Technology - Baseline for Cybersecurity Classification Protection (GB/T 22239-2019)
Information Security Technology - Technical Requirements of Security Design for Cybersecurity Classification Protection (GB/T 25070-2019)
Information Security Technology - Evaluation Requirements for Cybersecurity Classification Protection (GB/T 28448-2019).
Information Security Technology - Baseline for Cybersecurity Classification Protection (GB/T 22239-2019)
Information Security Technology - Technical Requirements of Security Design for Cybersecurity Classification Protection (GB/T 25070-2019)
Information Security Technology - Evaluation Requirements for Cybersecurity Classification Protection (GB/T 28448-2019).
The Administrative Measures for the Multi-level Protection of Information Security (MLPS) require all IT systems in China to be classified into different levels of security, from one to five (with the most sensitive systems designated as level 5). In 2019, the MLPS 2.0 (composed by GB/T 22239-2019, GB/T 25070-2019, and GB/T 28448-2019) has expanded the definition of 'information systems' to broader systems, including network infrastructure, cloud computing systems, mobile application platforms, connected devices and industrial control systems.
The MLPS 2.0 requires networks of level 3 and above to adopt network products and services appropriate to their security protection levels. Under the MLPS 2.0, companies must self-assess their security management and compliance, and such assessment results must be evaluated and endorsed by the MLPS regulatory body.
The MLPS 2.0 requires companies in China to set up their cloud infrastructure, including servers, virtualised networks, software, and information systems. Such cloud infrastructures are subject to testing and evaluation by the Chinese government. Overseas operation and maintenance of Chinese cloud computing platforms must also follow Chinese laws and regulations. The national standards also state that customers' data and users' personal information processed by cloud service providers should be stored inside China, which is an additional requirement. It is currently uncertain how these national standards would be enforced, and there have not yet been reports of enforcement.
The MLPS 2.0 requires networks of level 3 and above to adopt network products and services appropriate to their security protection levels. Under the MLPS 2.0, companies must self-assess their security management and compliance, and such assessment results must be evaluated and endorsed by the MLPS regulatory body.
The MLPS 2.0 requires companies in China to set up their cloud infrastructure, including servers, virtualised networks, software, and information systems. Such cloud infrastructures are subject to testing and evaluation by the Chinese government. Overseas operation and maintenance of Chinese cloud computing platforms must also follow Chinese laws and regulations. The national standards also state that customers' data and users' personal information processed by cloud service providers should be stored inside China, which is an additional requirement. It is currently uncertain how these national standards would be enforced, and there have not yet been reports of enforcement.
Coverage Information systems including network infrastructure, cloud computing systems, mobile application platforms, connected devices and industrial control systems
Sources
- https://web.archive.org/web/20231129222542/http://www.ustr.gov/sites/default/files/2014%20TBT%20Report.pdf
- https://web.archive.org/web/20240328031234/https://www.dataguidance.com/opinion/china-mlps-20-baseline-requirements-and-practical
- https://web.archive.org/web/20241202145636/https://www.amcham-shanghai.org/en/article/mlps-20-set-take-effect-december-1
- https://web.archive.org/web/20211125185807/https://assets.kpmg/content/dam/kpmg/cn/pdf/en/2019/05/mlps-insights-strategies.pdf
- https://web.archive.org/web/20230306020809/https://www.csis.org/analysis/how-chinese-cybersecurity-standards-impact-doing-business-china
- https://web.archive.org/web/20220706053414/https://www.tanovo.com/upload/sitearticle_file/208/%E3%80%90%E7%AD%89%E4%BF%9D2.0-%E6%AD%A3%E5%BC%8F%E5%8F%91%E5%B8%83%E7%89%88%E3%80%91GBT25070-2019%E4%BF%A...
- https://web.archive.org/web/20220129105239/https://www.djbh.net/webdev/web/HomeWebAction.do?p=getGzjb&id=8a81825674296d130174bdf702c8002e
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CHINA
Since July 2015
Pillar Technical standards applied to ICT goods and online services |
Indicator Product screening and additional testing requirements
National Security Law of the People's Republic of China (中华人民国国家安全法)
The National Security Law foresees the rollout of a “secure and controllable” internet infrastructure. Under the National Security Law, the State can establish national security review and oversight management systems and mechanisms, conduct a national security review of foreign commercial investment, special items and technologies, internet information technology produces and services, projects involving national security matters, as well as other major matters and activities, that impact or might impact national security.
Coverage Horizontal
Sources
- https://web.archive.org/web/20230202090346/http://www.xinhuanet.com//politics/2015-07/01/c_1115787097.htm
- https://web.archive.org/web/20231220170803/https://www.chinalawtranslate.com/en/2015nsl/
- https://web.archive.org/web/20231218162838/http://www.gov.cn/zhengce/2015-07/01/content_2893902.htm
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CHINA
Since October 2019, entry into force in January 2020
Pillar Technical standards applied to ICT goods and online services |
Indicator Restrictions on encryption standards
Cryptography Law of the People’s Republic of China (中华人民共和国密码法)
Art. 26 of the Cryptography Law stipulates that commercial cryptography products relating to national security, the national economy and the people’s livelihood, or the public interest, may be sold or otherwise made available for use only after passing testing and certification conducted by duly qualified bodies. Art. 27 further requires that, where operators of critical information infrastructure procure network products or services incorporating commercial cryptography that may affect national security, such products or services must undergo a national security review conducted jointly by the national cyberspace administration, the national cryptography administration, and other relevant authorities. Art. 28 provides that the department responsible for commerce under the State Council, together with the national cryptography administration, shall impose import licensing requirements, in accordance with the law, on commercial cryptography possessing encryption functions and bearing upon national security or the public interest; however, such licensing is not to apply to commercial cryptography used in mass‑consumption products. The legislation does not, however, clarify what constitutes commercial cryptography used in mass‑consumption products, thereby generating uncertainty as to how this significant exemption will operate in practice.
More generally, it is reported that there are onerous requirements on the use of encryption, including intrusive approval processes and, in many cases, mandatory use of indigenous encryption algorithms (e.g., for Wi-Fi and 4G cellular products).
More generally, it is reported that there are onerous requirements on the use of encryption, including intrusive approval processes and, in many cases, mandatory use of indigenous encryption algorithms (e.g., for Wi-Fi and 4G cellular products).
Coverage Horizontal
Sources
- https://web.archive.org/web/20250807143252/http://www.npc.gov.cn/englishnpc/c2759/c23934/202009/t20200929_384279.html
- https://web.archive.org/web/20231208065421/https://www.insideprivacy.com/data-security/china-enacts-encryption-law/
- https://web.archive.org/web/20260428020926/https://ustr.gov/sites/default/files/files/Press/Reports/2025NTE.pdf
- https://web.archive.org/web/20260404201644/https://ustr.gov/sites/default/files/2022%20National%20Trade%20Estimate%20Report%20on%20Foreign%20Trade%20Barriers.pdf
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CHINA
Since April 2009, entry into force in October 2009
Pillar Online sales and transactions |
Indicator Licensing scheme for e-commerce providers
Postal Law of the People's Republic of China (中华人民共和国邮政法)
According to Art. 51 of the Postal Law of the People's Republic of China, a specific license is needed for express delivery business. It is reported that the administrative licensing for express delivery services is non-transparent and burdensome, preventing competition. It is reported that as companies are required to apply to each city where there is a postal administration department, they need to go through at least 350 review and approval processes if they want to operate at the national level.
Coverage Express delivery services
Sources
- https://web.archive.org/web/20170915200941/https://www.europeanchamber.com.cn/en/publications-archive/374/Logistics_Position_Paper_2015_2016
- https://web.archive.org/web/20191203041332/http://www.asianlii.org/cn/legis/cen/laws/plotproc367/
- https://web.archive.org/web/20220320062912/http://www.gov.cn/flfg/2009-04/24/content_1295123.htm
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