How China’s Cybersecurity Review Poses Challenges to Foreign Suppliers - Barbara Li and Zhou Yang

China Law Podcast

Just as the United States has beefed up its scrutiny of the supply chains of its critical infrastructure in recent months, China has also launched a new cybersecurity review (CSR) for mitigating the national security risks posed by theirs. In this episode, Barbara Li and Zhou Yang explain the scope and process of the cybersecurity review, the basic steps parties must take in order to comply, the implications for foreign suppliers, and more.

Barbara Li is Head of Corporate at Rui Bai Law Firm in Beijing, where she spearheads the TMT and FinTech practices. She is also former vice chair of the Cybersecurity Sub-Working Group of the EU Chamber of Commerce in China.

Zhou Yang is a Shanghai-based partner at Zhong Lun Law Firm specializing in TMT and cybersecurity issues.

The China Law Podcast is a weekly podcast exploring China’s business and financial sectors from a legal perspective, hosted by Vincent Chow. Get in touch at [e-mail] with any feedback and ideas for future episodes.

Episode outline

• 02:01 Legal basis for the cybersecurity review under Cybersecurity Law and National Security Law
• 03:54 Scope of the review: CII operators' procurement of network products and services
• 08:10 What is required under pre-review self-evaluation
• 11:46 Punishments for non-compliance
• 16:43 Export control restrictions for U.S. suppliers
• 18:25 Situation where Chinese customer have no choice beyond U.S. supplier

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