PIPL
China's comprehensive regulation for personal information protection
FSSC 22000
GFSI-benchmarked certification scheme for food safety management.
Quick Verdict
PIPL mandates data protection for China operations, enforcing consent and transfers with hefty fines. FSSC 22000 certifies voluntary food safety systems via audits. Companies adopt PIPL for legal compliance, FSSC for market access and supply chain trust.
PIPL
Personal Information Protection Law (PIPL)
Key Features
- Extraterritorial scope for foreign processors targeting China
- Explicit separate consent required for sensitive PI
- Tiered cross-border transfer mechanisms with volume thresholds
- No legitimate interests basis for processing
- Fines up to 5% annual revenue or RMB 50 million
FSSC 22000
Food Safety System Certification 22000
Key Features
- Integrates ISO 22000 with sector PRPs and additional requirements
- GFSI-benchmarked for global food chain recognition
- Mandates food defense, fraud, and allergen management
- Covers manufacturing, packaging, logistics, and trading categories
- Requires PDCA-based FSMS with PRP verification
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
PIPL Details
What It Is
PIPL (Personal Information Protection Law) is China's first comprehensive national regulation on personal information, effective November 1, 2021, with 74 articles across eight chapters. It governs collection, processing, storage, transfer, and deletion of personal information (PI) of natural persons in China. Modeled partly on GDPR but consent-centric, it uses a risk-based approach emphasizing individual rights and national security.
Key Components
- Core principles: lawfulness, necessity, minimization, transparency.
- Rules for processing (consent, contracts), sensitive PI (SPI) (biometrics, health, minors under 14), cross-border transfers (SCCs, security reviews), individual rights (access, deletion), handler obligations (PIPIAs, audits).
- Intersects with Cybersecurity Law and Data Security Law.
- No certification but compliance mechanisms like CAC assessments.
Why Organizations Use It
Mandatory for entities handling Chinese PI, with fines up to RMB 50 million or 5% revenue. Enables China market access, builds consumer trust, reduces breach risks, supports global operations via compliant transfers. Strategic for MNCs in e-commerce, fintech, tech.
Implementation Overview
Phased framework: gap analysis, data mapping, policies, controls, monitoring (6-12 months). Applies to all sizes handling Chinese data, extraterritorially. Requires PIPOs, in-China reps for foreigners; ongoing audits, no formal certification.
FSSC 22000 Details
What It Is
FSSC 22000 (Food Safety System Certification 22000) is a GFSI-benchmarked certification scheme for Food Safety Management Systems (FSMS). It applies across food chain categories from primary handling to packaging and logistics, using a risk-based PDCA management system approach anchored in ISO 22000:2018.
Key Components
- **Three pillarsISO 22000:2018 (clauses 4-10), sector-specific PRPs (e.g., ISO/TS 22002 series), and FSSC Additional Requirements (e.g., food defense, fraud, allergens).
- Over 100 combined requirements with HACCP/OPRP/CCP hazard controls.
- Built on PDCA cycle; certification via licensed bodies per ISO 22003-1:2022.
Why Organizations Use It
- Meets retailer mandates and enables global market access.
- Reduces recalls, enhances supply chain trust via public register.
- Manages risks like adulteration, supports SDGs (e.g., food waste).
- Builds competitive edge through verified FSMS maturity.
Implementation Overview
- Phased: gap analysis, FSMS design, training, audits (Stage 1/2).
- Applies to all sizes in food sectors worldwide.
- Requires CB certification, annual surveillance, 3-year recertification.
Key Differences
| Aspect | PIPL | FSSC 22000 |
|---|---|---|
| Scope | Personal data protection, processing, transfers | Food safety management systems, PRPs, hazards |
| Industry | All sectors handling Chinese personal data | Food chain: manufacturing, packaging, logistics |
| Nature | Mandatory Chinese law, CAC enforcement | Voluntary GFSI-benchmarked certification scheme |
| Testing | DPIAs, compliance audits, security assessments | CB audits, surveillance, recertification cycles |
| Penalties | Fines to 5% revenue, business suspension | Loss of certification, no legal fines |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about PIPL and FSSC 22000
PIPL FAQ
FSSC 22000 FAQ
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