Standards Comparison

    CE Marking

    Mandatory
    1985

    EU marking for product conformity to harmonised legislation

    VS

    PIPL

    Mandatory
    2021

    China's comprehensive law for personal information protection

    Quick Verdict

    CE Marking declares product conformity for EEA market access, while PIPL mandates data protection for Chinese residents globally. Companies adopt CE for free trade; PIPL to avoid massive fines and enable China business.

    Product Safety

    CE Marking

    Conformité Européenne (CE) Marking

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Manufacturer's self-declaration of EU conformity
    • Enables free movement across EEA markets
    • Harmonised standards provide presumption of conformity
    • Risk-proportionate conformity assessment modules A-H
    • Requires 10-year technical documentation retention
    Data Privacy

    PIPL

    Personal Information Protection Law (PIPL)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • Extraterritorial scope for foreign processors targeting China
    • Explicit separate consent for sensitive personal information
    • Tiered cross-border transfer mechanisms with security reviews
    • Penalties up to 5% of annual revenue
    • Mandatory impact assessments for high-risk processing

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    CE Marking Details

    What It Is

    CE Marking (Conformité Européenne) is the EU's primary product compliance marking under the New Legislative Framework (NLF). It serves as a manufacturer's declaration that products meet essential health, safety, and environmental requirements in harmonised legislation like LVD, EMC, and Machinery Directive. Its risk-based approach scales conformity assessment from self-declaration to notified body involvement.

    Key Components

    • Essential requirements and harmonised standards (OJEU-published for presumption of conformity).
    • Conformity modules A-H (e.g., internal production control, EU-type examination).
    • Technical documentation, EU Declaration of Conformity (DoC), and CE affixing rules.
    • Post-market surveillance under Regulation (EU) 2019/1020; no central certification.

    Why Organizations Use It

    Mandated for EEA market access, it ensures free circulation across 30+ countries, mitigates liability, and builds stakeholder trust. Provides competitive scale, reduces country-specific approvals, and supports innovation via standards safe harbor.

    Implementation Overview

    Involves legislation mapping, risk assessment, testing/documentation, DoC issuance, and marking. Applies to manufacturers/importers in sectors like electronics/machinery; high-risk needs notified bodies. Self-assessment common for low-risk; timelines 6-12 months typical, with 10-year retention.

    PIPL Details

    What It Is

    Personal Information Protection Law (PIPL) is China's first comprehensive national regulation on personal information processing. Enacted August 2021, effective November 1, 2021, it governs collection, use, storage, transfer, and deletion of personal data. Applies domestically and extraterritorially to foreign entities targeting China. Employs a risk-based approach with consent-first defaults, alongside Cybersecurity Law and Data Security Law.

    Key Components

    • 74 articles in 8 chapters covering processing rules, cross-border transfers, individual rights.
    • Core principles: lawfulness, necessity, minimization, transparency, accountability.
    • Sensitive personal information (SPI) rules, DPIAs, seven legal bases (no broad legitimate interests).
    • Compliance via internal governance, CAC security reviews, SCCs; no universal certification.

    Why Organizations Use It

    • Mandatory for China-exposed firms; fines up to RMB 50M or 5% revenue.
    • Builds customer trust, enables market access, operational resilience.
    • Mitigates risks from enforcement, breaches; strategic for M&A, talent.

    Implementation Overview

    • Phased: assessment, policies, controls, monitoring (6-12 months).
    • All sizes/industries handling Chinese PI; training, audits essential.

    Key Differences

    Scope

    CE Marking
    Product safety, health, environmental compliance
    PIPL
    Personal data processing, privacy rights protection

    Industry

    CE Marking
    Manufacturing, electronics, machinery across EEA
    PIPL
    All sectors handling Chinese residents' data globally

    Nature

    CE Marking
    Manufacturer self-declaration, mandatory for scope
    PIPL
    Mandatory regulation with CAC enforcement, extraterritorial

    Testing

    CE Marking
    Conformity modules, notified body for high-risk
    PIPL
    PIIAs for high-risk, security assessments for transfers

    Penalties

    CE Marking
    Market withdrawal, fines via national authorities
    PIPL
    Fines up to 5% revenue, business suspension

    Frequently Asked Questions

    Common questions about CE Marking and PIPL

    CE Marking FAQ

    PIPL FAQ

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