(Source: https://pltfrm.com.cn)
Introduction
Moving Chinese user data outside mainland China has become one of the biggest pain points for overseas brands in 2025. New CAC regulations introduced in March 2025 tightened thresholds dramatically. Here are the three legal pathways—and exactly which one your brand should choose.
1. CAC Security Assessment (The Strictest Route)
1.1 When It’s Mandatory Volume Trigger: Handling personal information of more than 1 million individuals or sensitive personal information of 100,000+. CIIO Status: Automatically required if designated as critical information infrastructure.
2. Standard Contract Clause Filing (Most Popular for Mid-Sized Brands)
2.1 Step-by-Step Process Sign China SCC: Use the official template issued by CAC in 2023. Self-Assessment Report + Filing: Complete within 60 days of the contract taking effect.
3. Personal Information Protection Certification
3.1 Fastest Growing Option Third-Party Certification Bodies: Currently six authorized institutions (including China Cybersecurity Review Technology and Certification Center). Timeline Advantage: Usually completed in 8–12 weeks versus 6–18 months for security assessment.
4. Practical Implementation Tips
4.1 Data Mapping First Mandatory Exercise: Conduct full data flow mapping before choosing any route—most brands underestimate the volume of data collected via pixels and CDPs.
Case Study: Australian Health Supplement Brand’s Smooth SCC Filing
An Australian health supplement brand running large-scale Douyin and Tmall campaigns was transferring over 800,000 user records monthly to Sydney servers. We conducted data mapping, drafted and filed China Standard Contract Clauses with CAC, appointed a Beijing-based data representative, and implemented automatic data anonymization for non-essential fields. The entire process was completed in 42 days with zero disruption to ongoing campaigns.
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!
