43 China Localization Adaptations in Detail
Clause numbering consistent for international cross-reference. Legal citations complete for compliance review. Each adaptation labeled as based on mandatory GB or recommended GB/T.
About the Localization Adaptations
The Community Data Center Standard — China Edition maintains consistent clause numbering with the original international framework. However, for clauses not directly applicable under China's legal and governance system, localization adaptations have been made through Implementation Notes — describing the corresponding implementation mechanism in China, rather than directly deleting or replacing the original clause.
All 43 adaptations are organized into six categories. Each adaptation is labeled with:- [Mandatory GB]: Corresponding to mandatory national standards — must comply, no concessions
- [Recommended GB/T]: Corresponding to recommended national standards — providing best practice guidance
- [Regulation]: Corresponding to specific provisions of laws and regulations
- [Policy]: Corresponding to departmental rules or policy documents
⚠️ Legal Effect Notice: This framework is an industry initiative framework and carries no mandatory binding force. All [Mandatory GB] labels only indicate that the relevant mandatory national standards referenced by that clause themselves carry legal mandatory force. No clause of this framework replaces or exempts compliance obligations under mandatory national standards.
Six Adaptation Categories
I. Community Benefit Agreement (CBA) Localization (8 Items)
The international framework's "Community Benefit Agreement" (CBA) has no direct counterpart in China's legal system. Equivalent mechanisms are achieved through three established Chinese institutional systems:
| Adaptation # | Base Clause | China Implementation Mechanism | Legal Basis | Standard Type |
| CBA-1 | Community benefit agreement signing | Social Stability Risk Assessment (statutory prerequisite for major project approval) | [Regulation] NDRC Interim Measures for Social Stability Risk Assessment of Major Fixed Asset Investment Projects | — |
| CBA-2 | Community benefit consultation mechanism | Local government investment promotion evaluation framework — incorporating community benefit commitment assessment | [Policy] Local investment promotion assessment measures | — |
| CBA-3 | Community benefit fund | Special public welfare fund (Charity Law Arts. 46–49) or non-public CSR special funds | [Regulation] Charity Law (2023 revision) | — |
| CBA-4 | Community representative participation | Community local governance committee — including resident representatives and grassroots Party organizations | [Policy] Grassroots governance related documents | — |
| CBA-5 | Annual community audit | Independent third-party audit + audit report legally disclosed | [Regulation] Charity Law Art. 73 (public welfare fund information disclosure obligations) | — |
| CBA-6 | Local employment commitment | Employment indicators within the investment promotion evaluation framework | [Policy] Local employment promotion policies | — |
| CBA-7 | Local supply chain priority | Aligned with local government business environment optimization policies | [Policy] State Council Regulations on Optimizing the Business Environment | — |
| CBA-8 | Carbon credit community allocation | A portion of CCER carbon credit revenue attributed to the community | [Policy] To be finalized upon release of data center CCER methodology | — |
II. Data Security & CII Compliance (6 Items)
| Adaptation # | Base Clause | China Implementation Mechanism | Legal Basis | Standard Type |
| CII-1 | Real-time public dashboard | CII data centers replace public dashboards with regulatory reports; non-CII maintain public | [Regulation] Data Security Law Art. 21 | — |
| CII-2 | Data classification disclosure | Three-tier classification (Core / Important / General), matching differentiated disclosure requirements | [Regulation] Data Security Law Art. 21 | — |
| CII-3 | Cross-border data transfer | Three pathways: security assessment / standard contract / protection certification | [Regulation] Personal Information Protection Law Art. 38 | — |
| CII-4 | MLPS baseline | GB/T 22239-2019 MLPS 2.0 as mandatory baseline | [Mandatory GB] GB/T 22239-2019 | 🔴 Mandatory |
| CII-5 | CII security review | Critical Information Infrastructure security review (CII operators) | [Regulation] Regulations on the Security Protection of Critical Information Infrastructure | — |
| CII-6 | Data localization | Personal information and important data collected domestically by CII operators shall be stored within China | [Regulation] Cybersecurity Law Art. 37 | — |
III. Energy & Energy Efficiency Standards (8 Items)
| Adaptation # | Base Clause | China Implementation Mechanism | Legal Basis | Standard Type |
| ENE-1 | PUE threshold | ≤ 1.30 (general) / ≤ 1.20 (hub nodes) | [Mandatory GB] GB 40879-2021 | 🔴 Mandatory |
| ENE-2 | Renewable energy procurement | Green Electricity Certificate (GEC) trading + green electricity trading | [Policy] 发改能源〔2023〕1045号 | — |
| ENE-3 | New generation requirements | Source-Grid-Load-Storage integration — hub node new DCs ≥ 60% green electricity | [Policy] Implementation Opinions on Nationally Integrated Computing Power Network | — |
| ENE-4 | Energy efficiency certification | GB 40879-2021 Grade 1 energy efficiency (PUE ≤ 1.20) | [Mandatory GB] GB 40879-2021 | 🔴 Mandatory |
| ENE-5 | Carbon emission accounting | Aligned with national carbon emission dual-control system | [Policy] State Council 2024 Green Transition Opinions | — |
| ENE-6 | Demand-side response | Data centers incorporated into virtual power plant resource pools | [Policy] National Energy Administration Electricity Load Management Measures | — |
| ENE-7 | Compute-power coordination | Computing carbon emissions allocated by service flow | [Policy] NDRC pilot measures | — |
| ENE-8 | GEC cancellation | Completed through Beijing/Guangzhou Power Exchange Centers | [Policy] GEC trading system | — |
IV. Water Resources & Environmental Management (6 Items)
| Adaptation # | Base Clause | China Implementation Mechanism | Legal Basis | Standard Type |
| WAT-1 | Local watershed replenishment | Water rights trading + water infrastructure restoration — water conservation benefits equivalently credited | [Regulation] Water Law Art. 21 | — |
| WAT-2 | WUE threshold | ≤ 1.0 L/kWh (annual average) | [Recommended GB/T] Aligned with MIIT green data center indicators | 🟡 Recommended |
| WAT-3 | Water stress assessment | WRI Aqueduct or local authoritative assessment | [Policy] Local water resource management authorities | — |
| WAT-4 | Cooling method restrictions | Evaporative/once-through cooling prohibited in water-stressed areas | [Recommended GB/T] Environmental management related | 🟡 Recommended |
| WAT-5 | No water competition | Independent third-party hydrological impact assessment | [Regulation] Water Law water use priority order | — |
| WAT-6 | PFAS management | Reference international mainstream standards; China's New Pollutants Governance Action Plan | [Policy] New Pollutants Governance Action Plan | — |
V. Community Governance & Public Participation (8 Items)
Covers NIMBY mitigation, community communication mechanisms, information disclosure, dispute resolution, community satisfaction assessment, and related clauses. Each adaptation is anchored in China's grassroots governance system — including the Organic Law of Urban Residents Committees, the social stability risk assessment system, and local government open government requirements.
VI. Standards Referencing & Mutual Recognition (7 Items)
| Adaptation # | Base Clause | China Implementation Mechanism | Legal Basis | Standard Type |
| STD-1 | Base Standards references | Add parallel Chinese GB/GB-T standard references | [Mandatory GB]/[Recommended GB/T] Various relevant standards | 🔴/🟡 |
| STD-2 | ODCC mutual recognition | Interface with ODCC Green/Low-Carbon/Computing Power Level assessments | [Policy] ODCC assessment system | — |
| STD-3 | Green data center certification | Aligned with MIIT Green Data Center assessment | [Policy] MIIT notices | — |
| STD-4 | CCER methodology | Reserved interface for data center-specific methodology | [Policy] To be released by MEE | — |
| STD-5 | Association standard upgrade pathway | Collaborate with qualified social organizations to upgrade to formal association standard | [Regulation] Standardization Law Art. 18 | — |
| STD-6 | Base equivalence statement | Parallel and equivalent to the base standard, not subordinate | — | — |
| STD-7 | Compliance review currency | Policy effective dates + recommend readers conduct quarterly reviews | — | — |
⚠️ Note: The above is an adaptation category overview. The complete 43-item clause-by-clause mapping table with detailed legal citations is available in Appendix A.
Eternal Harmony is an AI research and development company. This is part of our public-interest research on technology infrastructure and community impact.
This framework is an independent initiative, not approved or endorsed by any government agency.