Cross-Border Data Compliance: A Comparative Analysis of the GDPR and China's PIPL for Enterprises

Abstract

This paper compares the EU’s GDPR and China’s PIPL, which share basic personal data protection rules but stem from conflicting core values: GDPR centers on individual privacy and free data movement, while PIPL prioritizes national security and data sovereignty. Such value gaps create severe cross-border compliance obstacles for multinationals, as exemplified by Uber’s hefty Dutch penalty stemming from conflicting cross-border transfer requirements. The research divides conflict-mitigation measures into four categories: technical improvement, institutional cooperation, corporate self-regulation and legal harmonization, and recommends a combined compliance strategy tailored for European and Chinese overseas businesses respectively. This study makes three key contributions by distinguishing formal legal similarity from practical compatibility, grounding analysis in real compliance scenarios and delivering a targeted coordination framework. Full unification of the two legal regimes is unrealistic given divergent social and political priorities behind their rules. Instead, the proposed framework helps multinationals reconcile disparate requirements, preserving cross-border data flow value while respecting EU personal rights and China’s security demands.