Direct answer

The China SCC is a CAC template plus a filing — not a rewritten EU SCC.

Where a CAC security assessment is not required, many handlers export PI by executing the official standard contract with the overseas recipient and filing it with the provincial CAC, together with a PIA. The template is not optional poetry: clauses on purpose, types, retention, onward transfer and individual rights are prescribed. Volume, CII and important-data triggers can kick you out of the SCC lane into assessment. Exemptions exist and move. This page does not reprint current numeric thresholds or portal URLs that rotate.

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

Are you still in the SCC lane?

Check current assessment triggers first.

Lane
02

Is the template the official one?

CAC standard contract, not a GDPR SCC.

Template
03

Has the PIA been done?

Filing pack expects it.

PIA
04

Where do you file?

Provincial CAC process — confirm current portal.

File

Working rule: Map the regulated role before marketing or launch in China.

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
EU SCC paste
Did you attach EU module 2 and call it China SCC?
Wrong instrument.
Stale threshold
Are you using a blog’s volume number?
Re-read current CAC measures.
Important data in the same pipe
Did you SCC a mixed important-data set?
Wrong lane.
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.

01Official templateCurrent CAC SCC text.
02PIA reportDated PIPL PIA for this export.
03Recipient fileWho, where, onward transfers, security.
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 filing approval?

It is a filing regime, not a silent licence — but CAC can object. Watch the current rules.

Can group companies skip it?

Intra-group is still an export if PI leaves the PRC. Certification is the other group-friendly tool.

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