PIPL
China's comprehensive law for personal information protection
REACH
EU regulation for chemicals registration, evaluation, authorisation, restriction.
Quick Verdict
PIPL governs personal data protection in China with strict consent and transfer rules for global firms serving Chinese users, while REACH mandates chemical registration and risk assessment for EU market access. Companies adopt both to ensure compliance, avoid massive fines, and secure market entry.
PIPL
Personal Information Protection Law (PIPL)
REACH
Regulation (EC) No 1907/2006 (REACH)
Key Features
- Industry-led registration of substances over 1 tonne/year
- Authorisation regime for SVHCs with sunset dates
- Binding restrictions on unacceptable risks (Annex XVII)
- Supply-chain SDS and exposure scenario communication
- Continuous evaluation and dossier update obligations
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), enacted November 1, 2021, is China's comprehensive national regulation governing collection, processing, storage, transfer, and deletion of personal information. It applies domestically and extraterritorially to organizations targeting Chinese individuals, emphasizing lawfulness, necessity, minimization, and risk-based protections for sensitive personal information (SPI) like biometrics and health data.
Key Components
- Eight chapters, 74 articles covering processing rules, cross-border transfers, individual rights, handler obligations.
- Core principles: consent-first (no broad legitimate interests), explicit SPI consent, data minimization, transparency.
- Transfer mechanisms: CAC security assessments, SCCs, certifications; localization for CIIOs.
- Compliance via PIPIAs, audits, DPO appointment for large handlers.
Why Organizations Use It
Mandated for China-exposed firms; avoids fines up to 5% revenue. Enhances trust, enables market access, reduces breach risks, supports resilient data architectures amid enforcement like Didi's RMB 1.2B penalty.
Implementation Overview
Phased: gap analysis, policies, controls, transfers (6-12 months). Targets multinationals, platforms; requires data mapping, consent UX, vendor clauses, ongoing audits—no formal certification but CAC reviews.
REACH Details
What It Is
REACH (Regulation (EC) No 1907/2006) is a directly applicable EU regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals. It shifts responsibility to industry to identify and manage chemical risks for human health and the environment, while fostering innovation. Scope covers substances, mixtures, and certain articles; approach is risk-based with tonnage-triggered data requirements.
Key Components
- Four pillars: Registration (dossiers >1 tonne/year), Evaluation (dossier/substance checks), Authorisation (SVHC permissions), Restriction (Annex XVII bans/limits).
- 17 annexes for data standards, lists (Annex XIV SVHCs), SDS rules.
- Principles: industry data generation, supply-chain communication, continuous updates.
- No certification; compliance via ECHA submissions, national enforcement.
Why Organizations Use It
- Mandatory for EU/EEA manufacturers/importers to ensure market access.
- Mitigates fines, bans, recalls; enables substitution, ESG reporting.
- Builds trust, reduces liability, drives competitive safer products.
Implementation Overview
- Phased: inventory, gap analysis, dossiers/CSRs, monitoring.
- Cross-industry, global via Only Representatives; data governance/training key.
- Audit-ready via self-assessments, national inspections. (178 words)
Key Differences
| Aspect | PIPL | REACH |
|---|---|---|
| Scope | Personal data collection, processing, transfer | Chemical substances registration, risk management |
| Industry | All sectors handling Chinese personal data | Chemicals, manufacturing, importers to EU |
| Nature | Mandatory China national privacy law | Mandatory EU chemicals regulation |
| Testing | DPIAs for high-risk processing | Dossier submissions, chemical safety assessments |
| Penalties | Up to 5% revenue or RMB 50M | Fines up to €10M or 2% turnover |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about PIPL and REACH
PIPL FAQ
REACH FAQ
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