What is the primary objective of **CSL (Cyber Security Law of China)**?

**The primary objective of CSL (Cyber Security Law of China) is to establish a nationwide statutory framework for securing information systems, enforcing network security, data localization, and cybersecurity governance for all entities processing data in China.** Enacted on **June 1, 2017**, its 69 articles mandate technical safeguards like firewalls and real-time monitoring (**network security**), storage of **Critical Information Infrastructure (CII)** and **important data** in Mainland China with assessments for cross-border transfers (**data localization & PIP**), and senior executive accountability with incident reporting (**cybersecurity governance**).

Who is legally or professionally required to comply with **CSL (Cyber Security Law of China)**?

**All network operators, CII operators, data processors of important data, and foreign enterprises serving Chinese users must comply with CSL (Cyber Security Law of China).** This includes entities owning networks for public services (e.g., **Tencent Cloud**), operating systems vital to national security or public welfare (e.g., power grids), handling large-scale personal or **State Council-designated important data** (e.g., e-commerce platforms), and foreign services like **Microsoft 365** with Chinese users.

Does **CSL (Cyber Security Law of China)** require an external audit or third-party certification?

**CSL (Cyber Security Law of China) requires government-approved security evaluations and certifications for CII operators, including third-party Security Protection Capability Test (SPCT) reports submitted to MIIT.** **Article 20** mandates penetration testing and vulnerability scanning; CII entities must obtain attestations from certified agencies, with optional **China Information Security Certification (CISC)** for audit readiness.

How often should an assessment for **CSL (Cyber Security Law of China)** be performed?

**CSL (Cyber Security Law of China) assessments must be conducted periodically, with security testing per Article 20, annual compliance reporting, and re-assessments within 60 days of regulatory amendments.** Continuous monitoring via SIEM and KPIs (e.g., % compliant assets) is required, alongside quarterly training and incident drills to meet the 24-hour reporting window under **Article 31**.

What are the consequences of non-compliance with **CSL (Cyber Security Law of China)**?

**Non-compliance with CSL (Cyber Security Law of China) incurs fines up to 5% of annual revenue, business license suspension, service shutdowns, and operational disruptions.** The 2022 amendment escalated penalties; examples include a CNY 150 million fine for data non-localization and temporary API blocks for cloud providers.

An **CSL (Cyber Security Law of China)** be mapped to other international frameworks?

**Yes, CSL (Cyber Security Law of China) can be mapped to international frameworks like ISO 27001 and NIST through aligned controls in gap analyses and policy suites.** Implementation frameworks cross-reference **Annex A** controls to CSL articles (e.g., **Article 21** network security), enabling hybrid compliance for MNCs via tools like SOAR and ZTA.

What is the first step to begin implementing **CSL (Cyber Security Law of China)**?

**The first step to implement CSL (Cyber Security Law of China) is Phase 0: securing executive sponsorship and conducting regulatory baseline mapping.** Establish a C-suite charter, cross-functional steering committee, and catalog applicable CSL articles with gap analysis using asset inventories and **Article 21/30** reviews.

What is the primary objective of **IFS Food**?

**IFS Food is a standard for auditing product and process compliance in relation to food safety and quality.** It assesses whether a manufacturer's processing activities produce products that are safe, legal, and compliant with customer specifications. Version 8 (April 2023) emphasizes a **Product and Process Approach (PPA)** with risk-based product sampling, traceability tests, and at least 50% audit time in production areas to verify operational controls like HACCP, PRPs, food fraud (4.20), and food defense (4.21).

Who is legally or professionally required to comply with **IFS Food**?

**IFS Food applies to food product manufacturers processing food products or packing loose food products where contamination risk exists.** It targets site-specific certification—one legal entity, one address—for post-farm supply chain operations, especially private-label suppliers to European retailers. Fully outsourced or traded products require IFS Broker; partly outsourced processes must be controlled and scoped explicitly.

Does **IFS Food** require an external audit or third-party certification?

**Yes, IFS Food mandates annual external audits by an ISO/IEC 17065-accredited certification body using approved auditors.** Audits follow the PPA with initial, recertification, follow-up, or extension types; unannounced audits occur at least every third audit. Certification issues at Higher Level (≥95%) or Foundation Level (≥75%-<95%) only if no unresolved KO or Major nonconformities.

How often should an assessment for **IFS Food** be performed?

**IFS Food requires a full recertification audit every 12 months.** Internal audits (KO 5.1.1) must cover the full scope annually, with management reviews at least yearly. Unannounced audits follow a minimum frequency of once every third audit since January 2021; extension audits address scope changes or non-running lines.

What are the consequences of non-compliance with **IFS Food**?

**Non-compliance with IFS Food results in scoring deductions, certificate denial, or withdrawal.** KO requirements scored D deduct 50% and block certification; Majors deduct 15%. Recertification failures withdraw certificates within two working days, notifying stakeholders via the IFS database. Unannounced access denial triggers immediate withdrawal.

An **IFS Food** be mapped to other international frameworks?

**No, IFS Food FAQs stand alone without mapping to other frameworks.** As a GFSI-benchmarked scheme, it shares foundational elements like HACCP but differs in audit frequency (annual), accreditation (ISO 17065), scoring (Higher/Foundation Levels), and unannounced rules from peers.

What is the first step to begin implementing **IFS Food**?

**The first step is to review the normative IFS Food Version 8 standard and Doctrine, then conduct a gap analysis against the audit checklist.** Appoint an IFS-approved, accredited certification body, define site-specific scope (all products/processes), and disclose prior certifications, outsourced processes, and exports for audit planning.

CSL (Cyber Security Law of China) vs IFS Food

Standards Comparison

CSL (Cyber Security Law of China)

Mandatory

N/A

China's statutory framework for network security and data localization

IFS Food

Voluntary

2023

Global standard for food safety and process compliance.

Quick Verdict

CSL mandates cybersecurity and data localization for China operations, enforcing compliance via heavy fines. IFS Food certifies food manufacturers' safety and quality processes through audits. Companies adopt CSL for legal survival in China; IFS for retailer access and trust.

Standard

CSL (Cyber Security Law of China)

Cybersecurity Law of the People's Republic of China

Cost

€€€

Complexity

Medium

Implementation Time

12-18 months

Key Features

Mandates data localization for CII and important data
Requires real-time network security monitoring and testing
Assigns cybersecurity responsibilities to senior executives
Enforces 24-hour incident reporting to authorities
Binds foreign entities serving Chinese users

Food Safety

IFS Food

IFS Food Version 8

Cost

€€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Product and Process Approach with audit trails
Risk-based HACCP and operational controls
Annual audits with ≥50% on-site evaluation
10 Knock-Out requirements for critical failures
Senior management governance and culture focus

Detailed Analysis

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

CSL (Cyber Security Law of China) Details

What It Is

Enacted on June 1, 2017, the Cybersecurity Law of the People’s Republic of China (CSL) is a nationwide statutory regulation comprising 69 articles. It governs network operators, service providers, and data processors in Chinese jurisdiction, focusing on securing information systems. The primary purpose is protecting network security, enforcing data localization, and establishing cybersecurity governance, using a control-based approach with risk assessments for critical infrastructure.

Key Components

Three pillars: Network Security (safeguards, testing, monitoring), Data Localization & Personal Information Protection (local storage for CII/important data), Cybersecurity Governance (executive duties, incident reporting).
Mandates technical controls, real-time monitoring, and cooperation with authorities.
Replaces sector-specific rules with a universal baseline.
Compliance via assessments, reporting, and evaluations for CII operators.

Why Organizations Use It

CSL is mandatory, with fines up to 5% of revenue, shutdowns, and legal risks for non-compliance. It builds trust, differentiates in markets, boosts efficiency through modern architectures like zero-trust, and enables innovation via local R&D and sandboxes. Enhances risk management and market access for Chinese users.

Implementation Overview

Phased framework: stakeholder alignment, gap analysis, architectural redesign (data centers, SIEM), governance/training, testing/certification. Applies to all network operators including foreign MNCs with Chinese users, across sizes/industries. Requires ongoing audits, reporting, and adaptation to updates like PIPL/DSL.

IFS Food Details

What It Is

IFS Food Version 8 is a GFSI-benchmarked certification standard for auditing product and process compliance in food manufacturing. It focuses on ensuring safe, legal, authentic products meeting customer specifications via a risk-based Product and Process Approach (PPA).

Key Components

Organized into governance, HACCP/PRPs, operational controls (e.g., allergens, fraud, defense), and performance monitoring.
Over 200 checklist requirements with 10 Knock-Out (KO) criteria.
Built on HACCP, prerequisite programs, and annual audits emphasizing on-site verification (≥50% time).
Two certification levels: Higher (≥95%) and Foundation (≥75%).

Why Organizations Use It

Meets European retailer demands for private-label supply.
Reduces multi-audit burden, enhances market access.
Mitigates risks like recalls, fraud; builds trust.
Drives continuous improvement via scoring and reviews.

Implementation Overview

Phased: gap analysis, FSMS design, training, validation, audits.
Applies to food processors globally, site-specific.
Requires accredited certification bodies, annual recertification, unannounced options.