数据跨境流动监管与企业供应链转移

Abstract

In the era where data constitutes a critical factor of production, cross-border data flows are widely regarded as a significant driver of global economic growth. However, attendant security concerns have prompted major economies to introduce various regulatory constraints on such flows. China's regulatory policies on cross-border data flows are significantly different from those of other countries and regions, such as the General Data Protection Regulation (GDPR). As China's regulatory framework for cross-border data flows becomes increasingly institutionalized and standardized, how will such policy developments impact corporate operations and strategic adaptations ? This study integrates the enterprise supply chain into the analytical framework and systematically examines how changes in regulatory policies influence adjustments within supply chains. Employing a difference-in-differences framework and leveraging the FactSet Revere database, the study finds that the evolving cross-border data flow policies have increased the costs for Chinese firms to maintain overseas customers, thereby encouraging a domestic reorientation of downstream supply chain segments. Simultaneously, these regulatory changes have intensified competition of domestic market, compelling firms reliant on foreign suppliers to adapt their operational strategies, which, in turn, has contributed to an outward shift in upstream supply chain activities. Heterogeneity analysis further reveals that the impact of China's cross-border data flow regulations on corporate supply chains is amplified when trading partner countries impose relatively fewer restrictions on data flows. Moreover, compared to state-owned enterprises, non-state-owned enterprises exhibit greater sensitivity to these regulatory changes. The paper also demonstrates that the effects of policy adjustments propagate along the supply chain, stimulating innovation among both upstream and downstream firms. Finally, the analysis suggests that enhancing innovation capabilities and improving firms’ positions within the supply chain can help mitigate the disruptions caused by regulatory changes. From a policy perspective, governments can support corporate adaptation through improved digital infrastructure and targeted innovation subsidies. Existing research has primarily focused on the effects of traditional trade instruments, such as tariffs, import and export controls, and trade agreements, on supply chain configurations. However, there remains limited attention to interaction with data governance regimes and global supply chains. While a growing body of work has begun to examine the implications of cross-border data flow policies, employing theoretical modeling and empirical analysis to investigate their transmission mechanisms and welfare effects, China’s regulatory approach differs markedly from prevailing international models. Based on the evolution of China's cross-border data flow policies, this paper explores how this policy affects corporate supply chains, providing new perspectives and empirical evidence for a further understanding of cross-border data flow policies. This paper offers several critical policy implications. First, it is essential to refine the regulation policies for cross-border data flows and implement facilitation measures. The outbound transfer of data involving national security, major public interests, and core critical data should be strictly controlled, so as to promote orderly cross-border data flows. Second, efforts should be made to promote the research and application of privacy-enhancing technologies. It is necessary to leverage special funds, tax incentives, and other policies to help enterprises achieve the dual goals of data value mining and security protection. Third, the alignment with international rules should be deepened. Proactive measures should be taken to participate in the global data governance system and promote the coordination of cross-border data flow rules under multilateral frameworks to achieve higher-standard opening up.