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 processing do you perform for customers?

Facts.

Facts
02

Marketplace vs pure tools?

Character.

Character
03

EDI more accurate?

separate service category.

EDI
04

FIE restrictions on the item?

Ownership.

FIE

Working rule: Classify the service by what it does: transaction or data processing may fall within ODP or transaction-processing, while EDI and other VATS categories have separate definitions.

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
Every API called ODP automatically
Over/under mapping.
Counsel.
Payment licence confused with VATS ODP
Different regimes.
Split.
Ignore SaaS feature creep
New triggers.
Remap.
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.

01Service description / API catalogueProcessing.
02Customer contractsWhose transactions.
03Entity licences heldCurrent stack.
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 this the same as EDI?

Related family, not identical. Open /edi-licence-in-china.

Where is SaaS mapping?

Open /saas-in-china.

Primary authorities

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

Ministry of Industry and Information Technology (MIIT)
Cyberspace Administration of China (CAC)
National laws database (NPC)
Telecom business catalogue / MIIT licensing