Standards Comparison

    PIPL

    Mandatory
    2021

    China's comprehensive law for personal information protection

    VS

    AS9120B

    Mandatory
    2016

    Aerospace QMS standard for distributors ensuring traceability and counterfeit prevention.

    Quick Verdict

    PIPL mandates privacy protection for personal data in China with extraterritorial reach and hefty fines, while AS9120B is a voluntary QMS certification for aerospace distributors ensuring traceability and counterfeit prevention. Companies adopt PIPL for legal compliance, AS9120B for market access.

    Data Privacy

    PIPL

    Personal Information Protection Law (PIPL)

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

    Key Features

    • Extraterritorial scope for foreign entities targeting China
    • Consent-first model without legitimate interests basis
    • Volume-threshold cross-border transfer mechanisms
    • Explicit consent required for sensitive personal information
    • Penalties up to 5% of annual revenue
    Quality Management

    AS9120B

    AS9120B: Quality Management Systems for Distributors

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

    Key Features

    • Prevents counterfeit and suspected unapproved parts
    • Ensures traceability for split lots and chain-of-custody
    • Strengthens external provider controls and flowdown
    • Implements configuration management for distribution
    • Risk-based planning addressing distribution hazards

    Detailed Analysis

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

    PIPL Details

    What It Is

    Personal Information Protection Law (PIPL) is China's comprehensive national regulation enacted in 2021, effective November 1. It governs collection, processing, storage, transfer, and deletion of personal information with extraterritorial reach. Modeled partly on GDPR, it uses a risk-based approach emphasizing consent, minimization, and security.

    Key Components

    • Eight chapters, 74 articles covering processing rules, cross-border transfers, individual rights.
    • Core principles: lawfulness, necessity, minimization, transparency, accountability.
    • Sensitive personal information (SPI) like biometrics, health data requires explicit consent.
    • Compliance via data inventories, PIPIAs, appointed PIPOs for large handlers; no formal certification but CAC security reviews.

    Why Organizations Use It

    • Mandatory for entities handling Chinese residents' data; fines up to 5% revenue or RMB 50M.
    • Mitigates operational disruptions, enables market access, builds trust.
    • Enhances resilience, supports cross-border business via SCCs.

    Implementation Overview

    Phased framework: gap analysis, policies, controls, monitoring (6-12 months). Applies to all sizes, industries touching China; prioritizes multinationals, platforms.

    AS9120B Details

    What It Is

    AS9120B is the SAE International standard for quality management systems (QMS) tailored to aviation, space, and defense distributors. It augments ISO 9001:2015's high-level structure with over 100 aerospace-specific requirements, focusing on risk-based thinking to address distribution risks like traceability loss and counterfeit parts. Its scope covers organizations procuring, storing, splitting, and reselling parts without altering characteristics.

    Key Components

    • Core pillars: context analysis, leadership, planning, support, operations, performance evaluation, improvement.
    • Distribution emphases: counterfeit prevention, traceability, configuration management, external provider controls.
    • Built on ISO 9001:2015 PDCA cycle; requires documented information, not a full manual.
    • Certification via accredited bodies, listed in IAQG OASIS.

    Why Organizations Use It

    Provides market access to OEMs/Tier-1s, reduces supply chain risks, builds customer trust. Though voluntary, often contractually required; enhances efficiency, prevents nonconformities.

    Implementation Overview

    Phased approach: gap analysis, process design, training, audits (6-12 months). Applies to distributors globally; involves cross-functional teams, IT for traceability.

    Key Differences

    Scope

    PIPL
    Personal information processing, privacy rights, cross-border transfers
    AS9120B
    Aerospace distribution QMS, traceability, counterfeit prevention

    Industry

    PIPL
    All sectors handling Chinese personal data, global extraterritorial
    AS9120B
    Aerospace parts distributors, aviation/space/defense supply chains

    Nature

    PIPL
    Mandatory national law, CAC enforcement, extraterritorial regulation
    AS9120B
    Voluntary certification standard, IAQG QMS based on ISO 9001

    Testing

    PIPL
    DPIAs for high-risk, CAC security reviews, compliance audits
    AS9120B
    Internal audits, management reviews, third-party certification audits

    Penalties

    PIPL
    Fines up to 5% revenue or RMB 50M, business suspension
    AS9120B
    Loss of certification, market exclusion, no direct legal fines

    Frequently Asked Questions

    Common questions about PIPL and AS9120B

    PIPL FAQ

    AS9120B FAQ

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