On the 1st June, China’s new Cybersecurity Law come into force, which may have an impact on how companies deliver web services into China. Existing internet regulations in China have also been bolstered in recent months, adding further complexity for companies who want to successfully deliver content into the region.
CDNetworks specialises in content delivery and cloud security solutions, and is an expert in the Chinese market. In light of the latest changes, we have compiled a list of requirements and outlined the steps businesses need to take to ensure you are compliant when using a CDN service for China.
An ICP Bei’An is required for any domain delivering content from and within mainland China. It has been a requirement for any website in China since 2000 and it has always been a mandatory requirement for using a CDN in China.
The Chinese government requires any domain serviced through network infrastructure in China to have an ICP (Internet Content Provider) Bei’An. This is provided by the MIIT (Ministry of Industry and Information Technology) in China. The requirements to be issued an ICP Bei’An are complex, and the domain owner needs to make sure that they comply. They also need to ensure that the information provided for it is kept up to date and correct. The MIIT regularly checks the ICP Bei’An to ensure the requirements are met, and may cancel it at any time if the domain fails to meet these requirements. The Chinese government requires that the representative domain with an ICP Bei’An must have an IP that resolves within mainland China, and corresponds to the entity responsible. The representative domain has to be provided when applying for the ICP Bei’An.
Please note: From January 2018 ICP Bei’An Applications only accept domains which are registered with a Chinese registrar.
The new Cybersecurity Law is designed to protect the personal information of Chinese citizens, and depending of the data being collected, your website may need to be hosted in mainland China.
Given the broad interpretation of what personal data information could entail, we advise our customers to seek legal counsel, and if necessary, speak with the Chinese government to determine if hosting your domains in China is a requirement of the new Cybersecurity Law.
Hosting in China can also help overcome issues with latency, but will not overcome all latency issues in China. Regardless of where content is hosted, a specialist CDN for China is necessary to offer great web performance to users in the region.
The Chinese government requires all domains serviced through the network infrastructure in China to have a PSB (Public Security Bureau) Bei’An and to apply for it within 30 days of the launch of the web service. The PSB Bei’An is similar to the ICP Bei’An, but is provided by the CPSB (Chinese Public Security Bureau) in China.
1. Local coverage – A CDN partner will need to have a local, existing CDN infrastructure with as many nodes as possible to accelerate content and deliver good web performance in China. A partner will also need to be able to understand and deal with the north-south divide.
2. Knowledge of the Chinese market – A partner will need to understand in, detail, the requirements for the necessary licenses, and will ideally be authorised by the Chinese government to be a registrar and obtain the ICP Bei'An. A partner should also know how to deal with the fast-moving regulation landscape in China, and help keep its customers compliant.
3. Local relationships – a CDN partner must have excellent relationships with local ISPs and network peering points in order to route web services for minimal latency.
4. Global operations – A partner will need to be able to deliver content in and out of China, have a local point of contact that can deal directly with your services in China, as well as have global SLAs for end-to-end delivery.
5. Hosting in China – This depends on the type of web services you’d like to operate in China and how the Cybersecurity Law will evolve, but ideally, your CDN partner will also offer hosting in China. If a Chinese hosting service becomes necessary, then a CDN partner who can supply this without fuss is ideal.
6. Honesty and fairness - The requirements to deliver a website in China are far from straightforward. Some CDN and hosting partners will cut corners and risk your website from either being delivered, blocked, or blacklisted. It’s important to work with a CDN partner that is willing to help deal with these complex regulations and avoid this risk.
If you have any questions, please do not hesitate to contact us.
Each customer shall comply with all applicable laws, including the applicable laws, rules, regulations, and policies of the People’s Republic of China (collectively, “China Applicable Laws”) with respect to the Customer Content and such customer’s use of CDNetworks’ services or networks. Each customer is solely responsible for obtaining the necessary licenses and authorizations, including those required by the People’s Republic of China (“PRC”), for such customer’s business operations, its domains, and its use of CDNetworks’ services or networks in the PRC, including the payment of all fees required by governmental agencies in the PRC. CDNetworks reserves the right to suspend or terminate any use of or access to any of its services or networks (or reroute the services through a different network) if CDNetworks in its sole discretion believes any use of or access to the services or networks may result in a violation of any applicable laws, regulations, or policies, or if a customer fails to maintain appropriate licenses or authorizations. “Customer Content” includes content (including data, audio, graphic, text, and video), information or other materials of a customer or such customer’s clients, agents, or any other users provided by or through the customer to CDNetworks or that are transmitted, received, posted, stored, hosted, cached, or displayed on or through the CDNetworks network or other property of CDNetworks, or in connection with CDNetworks’ services. In connection with CDNetworks’ services to a customer, CDNetworks may, at its discretion, assist such customer with complying with a China Applicable Law applicable to the Customer Content and the customer’s use of CDNetworks’ services and networks, but such assistance is based only on CDNetworks' working knowledge and does not constitute legal advice. CDNetworks disclaims all liabilities arising out of such assistance or a customer’s noncompliance with China Applicable Laws. CDNetworks does not make any representation or warranty regarding its assistance or the accuracy or reliability of any statements or materials regarding compliance with China Applicable Laws, and does not guarantee that a customer will be in compliance with China Applicable Laws.