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

Is there a catalogue or sector list?

MIIT, PBOC, auto, industrial, local lists.

Catalogue
02

Are you a CIIO?

CII identification changes localisation and export.

CII
03

Is it also PI?

Then PIPL plus DSL may both apply.

Overlap
04

Is export even on the table?

Map the overseas recipient, access method and business need before testing the mandatory CAC assessment route.

Export

Working rule: The Data Security Law requires classification. Important data is data that, if tampered with, destroyed, leaked or illegally obtained or used, may endanger national security, economic operation, social stability or public health and safety — as further specified by regional and sectoral catalogues.

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
Board ‘crown jewels’
Did you label source code ‘important data’ with no catalogue?
Trade secrets are not automatically important data.
SCC for everything
Are you filing an SCC for a dataset a ministry listed?
Wrong tool.
One national list
Are you waiting for a single PRC-wide PDF?
Identification is often sectoral and local.
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.

01Sector and regionIndustry regulator and where systems sit.
02Catalogue checkDated sector/local important-data identification rules.
03CII statusWhether the operator has been identified.
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 employee HR data important data?

Usually no by default. It is still PI under PIPL.

Does localisation mean the data can never leave?

Not always. It often means storage in China plus a gated export path.

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