GDPR Compliance for Chinese Companies

Chinese companies operating internationally face a dual compliance challenge: China’s Personal Information Protection Law (PIPL) and the EU’s GDPR. Both have extraterritorial scope and require a local representative. For Chinese businesses serving EU customers, GDPR Article 27 requires an EU Representative.

PIPL vs GDPR — The Double Challenge

China’s PIPL (2021) requires companies processing Chinese personal data to appoint a local representative in China — conceptually similar to GDPR Article 27. However, PIPL’s data localisation requirements, cross-border transfer restrictions, and government access provisions create conflicts with GDPR frameworks that Chinese companies must navigate.

GDPR Article 27 for Chinese Companies

If your Chinese company offers goods or services to EU customers, monitors EU individuals, or processes EU personal data, GDPR Article 27 requires you to appoint an EU Representative. This must be a person or entity established in an EU member state — not in China.

Chinese Industries Most Exposed

• E-commerce & cross-border retail: Alibaba, AliExpress, Shein, Temu — all process EU customer data directly
• Technology & SaaS: Chinese software and app developers with EU users
• Manufacturing & export: Chinese factories and exporters with EU buyer contact data
• Gaming: Chinese gaming companies with EU player bases, handling user data and in-app purchases

Cross-Border Data Transfer Complexity

China does not have an EU adequacy decision. Transferring EU personal data to China requires: Standard Contractual Clauses (SCCs), PIPL security assessment for cross-border transfers, and an EU Representative. This is a complex dual-compliance scenario.

3-Step Compliance

1. Appoint EU Shield as your EU Representative — we provide EU legal presence
2. Document processing — ROPA covering both PIPL and GDPR requirements
3. Establish transfer mechanisms — SCCs for EU-to-China data flows + PIPL approval where required

See Pricing →