The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

01

What is leaving China?

PI, SPI, important data, or mixed.

Data
02

Who is the exporter?

CIIO vs ordinary handler vs group HQ.

Exporter
03

Which path is open?

Assessment, SCC, certification, or a current exemption.

Path
04

Did the threshold move?

Resolve the did the threshold move question separately before choosing the route.

Date

Working rule: If you provide personal information collected in China to a recipient outside the PRC, you are generally in a regulated export.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Volume folklore
Are you using a remembered ‘1 million’ rule without the current text?
CAC measures have been amended; re-read them.
Vendor in Hong Kong / Singapore
Is ‘Greater China’ treated as domestic?
Hong Kong and overseas are generally outside Mainland for export purposes.
Important data labelled as PI
Did you skip assessment because it is ‘only customer PI’?
Important-data export is a different gate.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Data mapCategories, volume band, storage location, recipients.
02Current CAC textDated copy of measures / Q&A / FTZ list if claimed.
03Contract pathDraft SCC vs assessment questionnaire vs certification body.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Is a US DPA enough?

No. A GDPR DPA does not replace a PIPL export tool.

Where are the numeric thresholds?

In the current CAC measures. This page will not reprint a number that can stale overnight.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

PIPL (NPC / official text)
Cyberspace Administration of China
National laws database (NPC)
Gov.cn policy releases