As the implementation of Chinas first comprehensivecybersecurity law1 (the CCL) progresses,concern is mounting in the international businesscommunity regarding the laws expansive scope, prescriptiverequirements and lack of clarity on a rangeof critical issues. Vocalizing such concern, the U.S.government asked Cvhina to halt its implementationof the CCL and highlighted potential issues with theCCL to members of the World Trade Organization.The CCL, officially entitled the Pl^C NetworkSecurity Law, was adopted in November 2016 withthe stated goal of protecting Chinese cyberspacesovereignty and ensuring network security withinChina. Since its passage, several regulations have beenreleased by the principal agency responsible for itsimplementation, the Cyberspace Administration ofChina (the CAC).2 These regulations were intendedto implement the provisions of the CCL, but in somecases appear to have further expanded its scope whileleaving some critical questions unanswered. In theface of such uncertainties, foreign companies operatingin China are advised to familiarize themselveswith the requirements of the CCL and its implementationrules and adopt measures to enhance theirpreparedness for the full implementation of the CCL.
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