China PIPL Compliance Checklist 2025: Avoid Million-Yuan Fines

(Source: https://pltfrm.com.cn)

Introduction

Since PIPL took effect in 2021 and was strengthened in 2024–2025, overseas brands have faced an avalanche of investigations. The average fine now exceeds 8 million RMB, and many campaigns are forced offline within hours. This practical checklist shows exactly what you need to have in place before launching any digital activity in China.

1. Privacy Policy & Consent Management

1.1 Mandatory Content in Privacy Policy Separate Sections: Must clearly distinguish personal information collection, usage, storage duration, cross-border transfer, and third-party sharing. Chinese Language First: The Chinese version takes legal precedence over English.

2. Cookie & Pixel Compliance on Chinese Platforms

2.1 Local Pixel Replacement Mandatory Switch: Google Analytics, Meta Pixel, and AppsFlyer must be replaced or supplemented with Tencent TAG, ByteDance Volcano, or Alibaba Tanx. Consent Before Activation: Tracking cannot start until the user actively agrees.

3. Data Localization & Storage Requirements

3.1 Important Data & Core Data Rules Local Storage Obligation: Health data, biometric data, and transaction data of over 1 million users must be stored in mainland China. Network Requirements: Many brands choose Alibaba Cloud or Tencent Cloud China regions with dedicated lines for compliance.

4. Incident Response & Reporting

4.1 72-Hour Breach Notification Mandatory Timeline: Any data breach affecting Chinese users must be reported to CAC within 72 hours, followed by user notification.

Case Study: U.S. Fashion Retailer’s 72-Hour PIPL Turnaround

During a routine CAC inspection, a major American fast-fashion brand was found using overseas servers without filing cross-border transfer agreements. We immediately deployed a China-based data representative, migrated key user data to Alibaba Cloud within 48 hours, filed SCCs, and updated all privacy policies across Tmall Global and Douyin stores. The brand avoided suspension and passed re-inspection in record time.

PLTFRM is an international brand consulting agency that works with companies such as Red, TikTok, Tmall, Baidu, and other well-known Chinese internet e-commerce platforms. We have been working with Chile Cherries for many years, reaching Chinese consumers in depth through different platforms and realizing that Chile Cherries’ exports in China account for 97% of the total exports in Asia. Contact us, and we will help you find the best China e-commerce platform for you. Search PLTFRM for a free consultation!

info@pltfrm.cn

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