---
title: "The Negative-List Map, Region by Region: Ten Zones, Two Models, and the Year Data Export Went Province-Wide"
author: "DCC Editorial"
published: 2026-07-09T01:00:00.000Z
url: https://datacompliancechina.com/posts/data-export-negative-lists-2026-national-registry/
description: "As of July 2026, ten Chinese regions — nine free-trade zones plus the Hainan Free Trade Port — have published data-export negative lists under Article 6 of the 2024 Cross-border Data Flows Provisions, and this year Beijing and Shanghai took the mechanism province- and city-wide, off the FTZ footprint entirely. DCC's roundup maps the full set: which sectors each zone lists (from Tianjin's 13 commodity categories to Guangdong's smart-manufacturing and personal-credit fields, Chongqing's intelligent-connected-vehicle chain, and Jiangsu's biopharma-only list), the two management models that have crystallized — pre-export filing versus Shanghai and Guangdong's 'transfer-first, report-after' — and how an overseas team should read the map. Compiled from the CAC's national negative-list index and each region's official notice, and paired with DCC's new downloadable negative-list registry."
tags: ["cross-border", "negative-list", "ftz-negative-list", "important-data", "data-economy"]
laws_cited: ["cross-border-data-flows-provisions", "data-export-security-assessment-measures", "personal-info-standard-contract-measures", "cross-border-pi-certification-measures"]
domains: ["cross-border", "data-economy"]
account: "wangxin-china"
original_title: "数据出境负面清单（国家网信办专栏）"
original_author: "中央网络安全和信息化委员会办公室 (Cyberspace Administration of China)"
original_publication: "国家网信办「数据出境负面清单」专栏 (CAC official column)"
original_url: "https://www.cac.gov.cn/wxzw/sjzl/sjcjfmqd/A09370806index_1.htm"
source_language: "zh"
---

> **Source: Data Compliance China** — https://datacompliancechina.com/posts/data-export-negative-lists-2026-national-registry/ · China data law, translated and annotated for overseas counsel. Cite as: Data Compliance China, "The Negative-List Map, Region by Region: Ten Zones, Two Models, and the Year Data Export Went Province-Wide", https://datacompliancechina.com/posts/data-export-negative-lists-2026-national-registry/
> *Editor's Note — DCC.*
>
> This is a DCC-compiled roundup, not a translation of a single article. It
> maps the data-export **negative lists** in force as of **July 2026**, drawing
> on the Cyberspace Administration of China's official
> [negative-list index](https://www.cac.gov.cn/wxzw/sjzl/sjcjfmqd/A09370806index_1.htm)
> — which records each region's filing with the national CAC and National Data Administration —
> and on each region's own issuing notice. It is the companion to DCC's new
> **[Data-export negative-list registry](/resources/negative-lists)**, where
> every list below is catalogued with its scope and official source and the
> originals can be downloaded.
>
> For the *mechanism* — how a negative list works and the structural patterns
> across zones — see DCC's explainer,
> [FTZ Data Export Negative Lists — How 17 Sectors Now Identify Important Data](/posts/compliance-talker-ftz-negative-lists-important-data/).
> This brief is the current-state map that explainer's August-2025 snapshot has
> since outgrown.

## What changed since the last count

When DCC last mapped this in August 2025, seven free-trade zones had published
negative lists. Eleven months later the count is **ten regions**, and the more
important shift is qualitative: in 2026 the mechanism **left the free-trade-zone
footprint**. Beijing extended its list to the whole municipality (the FTZ plus
the National Service-Sector Opening Demonstration Zone — the "Two Zones"), and
Shanghai extended eligibility city-wide, so an enterprise no longer needs to be
registered inside a bonded zone to use the negative-list path. The
[first Shanghai filing](/posts/shanghai-data-export-negative-list-first-filing/)
— Inditex's China arm, cleared in June 2026 — ran through Jing'an District, not
Pudong. What began in Tianjin in 2024 as an FTZ experiment is now, in its two
largest adopters, a province-level regime.

## The map as of July 2026

All of these rest on **Article 6** of the
[2024 Provisions on Promoting and Regulating Cross-border Data Flows](/laws/cross-border-data-flows-provisions/):
data **on** a list needs the standard CAC pathway — a
[security assessment](/laws/data-export-security-assessment-measures/), a
[Personal Information Standard Contract](/laws/personal-info-standard-contract-measures/)
filing, or [protection certification](/laws/cross-border-pi-certification-measures/);
data **off** it flows freely.

| Region | Version | Sectors listed | Model |
|---|---|---|---|
| **Guangdong** (FTZ) | 2025 | Smart-equipment manufacturing; personal credit reporting | Post-export |
| **Beijing** (province-wide) | 2025 | Automotive, pharma, civil aviation, retail, AI, medical devices, autonomous driving, trade logistics, banking | Pre-export |
| **Shanghai** (city-wide) | 2025 | Reinsurance, international shipping, commerce, meteorology, retail | Post-export |
| **Fujian** (FTZ) | 2025 | Medical/pharma, connected vehicles, retail, aircraft maintenance | Pre-export |
| **Chongqing** (FTZ) | 2025 | Intelligent connected vehicles | Pre-export |
| **Guangxi** (FTZ) | 2025 | Geo-info & meteorology, enterprise credit, livestream e-commerce, overseas A/V | Pre-export |
| **Jiangsu** (FTZ) | 2025 | Biopharmaceutical | Pre-export |
| **Zhejiang** (FTZ) | 2024 | Cross-border e-commerce (B2B), clearing & settlement | Pre-export |
| **Hainan** (Free Trade Port) | 2024 | Deep-sea, aerospace, seed industry, tourism & duty-free | Pre-export |
| **Tianjin** (FTZ) | 2024 | Strategic goods, natural resources, industrial, financial | Pre-export |

Scope figures, issuing bodies, and the official source for each are on the
[registry](/resources/negative-lists). A few are worth pulling out. Beijing's
2025 list is the broadest by far — **9 industries, 67 scenarios, 612 data
fields** — and reads as the reference catalogue other zones borrow from.
Shanghai's is the most operationally proven, with the first completed filing on
the books. At the other end, several 2025 lists are deliberately **single-
sector**: Chongqing lists only intelligent connected vehicles (4 business
activities, 9 scenarios, 110 data items across the full ICV chain); Jiangsu
lists only biopharmaceutical data, and reports cutting end-to-end export
timelines for it by 30–50%.

## Two models have crystallized

The zones have split into two administrative models, and the difference is
practical, not cosmetic:

- **Pre-export filing** — the enterprise applies to, and files with, the FTZ
  administrator *before* transferring; the zone confirms the data's status and
  the standard CAC pathway (where required) follows. This is the original
  Tianjin/Beijing/Zhejiang pattern, and it is what Fujian adopted — with a
  three-year validity on an approved filing.
- **Post-export reporting** — the enterprise self-assesses against the list,
  transfers, and *then* reports to the local cross-border data service centre.
  Shanghai (report within 15 working days) and Guangdong (先用后报, "use first,
  report after") are the two examples. It front-loads less friction, at the
  cost of putting the classification judgment squarely on the enterprise.

For a compliance team, the model determines whether the negative list is a
*gate* you pass through before shipping data or a *safe harbor* you document and
report into. Same instrument, materially different operational posture.

## Sector logic — each zone plays to its economy

The lists are not uniform national catalogues; each zone lists the sectors that
match its strategic role. Reinsurance and international shipping in Shanghai;
intelligent connected vehicles in Chongqing (China's largest vehicle-producing
municipality); biopharma in Jiangsu; deep-sea, aerospace and seed data in
Hainan; geographic-information and ASEAN-facing livestream commerce in Guangxi;
smart-equipment manufacturing and personal-credit reporting in Guangdong. The
same industry can appear in several zones with **different scope** — retail
"member management" data is listed in Shanghai, Fujian and Beijing, but Hainan's
retail entry is scoped to duty-free and clearance shopping. The practical
consequence: the zone whose list you read matters as much as the sector.

## What overseas teams should do with the map

1. **Check whether your sector is now listed somewhere — then check where you
   sit.** Because a negative list doubles as a public
   [important-data](/glossary) catalogue for its sector, the lists are the best
   sector-specific identification reference in existence, even for enterprises
   outside every zone. If your data falls **off** a relevant list, that is the
   argument for free flow; if it falls **on**, the standard pathway applies.
2. **Re-test entities in Beijing and Shanghai first.** These two are no longer
   FTZ-gated. A Beijing- or Shanghai-registered entity in a listed sector may
   have moved a tier — from security assessment down to a standard-contract
   filing, or from a filing down to exemption — without relocating anything.
3. **Read the model, not just the list.** A pre-export zone means file before
   you ship; a post-export zone (Shanghai, Guangdong) means you may ship and
   report, but you own the classification call.
4. **Treat the map as provisional.** Every list provides for dynamic revision
   and for new sectors to be added; Guangdong's even lets it borrow other zones'
   lists. Monitor the issuing bodies and re-review at least annually — or watch
   the [registry](/resources/negative-lists), which DCC updates as lists move.

The direction of travel is clear enough: a two-track cross-border regime —
standard CAC pathways nationwide, plus a widening negative-list track that, in
Beijing and Shanghai, is no longer confined to the zones at all. Multinationals
that map their China data footprint against it will operate at materially lower
friction than those that ignore it.

---

— Compiled by DCC from the Cyberspace Administration of China's
[data-export negative-list index](https://www.cac.gov.cn/wxzw/sjzl/sjcjfmqd/A09370806index_1.htm)
and each region's official issuing notice (linked from the
[registry](/resources/negative-lists)), July 2026.

*Not legal advice. Scope figures are transcribed from official notices and
their policy Q&As and may be partial; the published lists and their supporting
measures are authoritative. Verify the current version against the official
source before relying on any entry.*