Outbound Call Regulations in China

"Refuse Call" System: Regulators are moving toward an official DNC mechanism. In 2020, the Ministry of Industry and Information Technology (MIIT) released a draft rule to establish a nationwide "Refuse Call" platform (谢绝来电) for consumers to register their wish not to receive marketing calls. MIIT has instructed China's telecom carriers to provide easy opt-out services. For example, China Telecom's "Tianyi Anti-Harassment" service allows users to register their phone number and indicate their willingness (or refusal) to accept marketing calls/SMS. This system logs user preferences and will block commercial calls that go against a user's stated wish. Calls from numbers listed in MIIT's official telemarketing number database (the "主体库") that violate user preferences, or abnormal high-frequency calls from unregistered numbers, are automatically intercepted. Companies running outbound campaigns are expected to respect these registered preferences, or their calls may be blocked by the network.

Company Obligations: Outbound call centers should maintain internal do-not-call lists of any consumers who withdraw consent or complain, and scrupulously avoid contacting them. MIIT guidelines from 2018 emphasized that telemarketers must obtain user consent, maintain a whitelist of consenting users, retain proof of consent (and other call records), and restrict call behavior and timing. In practice, this means companies should only call numbers of individuals who have explicitly opted in (e.g. via web forms or prior agreement) and must immediately stop calling anyone who opts out. Businesses that violate these requirements face penalties under various laws (for instance, fines up to RMB 500,000 under the consumer protection law for infringing personal data rights).

No-call Timing and Etiquette: While not codified in detail, regulators expect reasonable calling hours and conduct. The 2018 MIIT action plan sought to "regulate the time and conduct of calls" – implying that call centers should avoid contacting consumers at off-hours (e.g. late at night or early morning) and must refrain from aggressive or harassing call practices. Repeated unwanted calls can be deemed "harassing calls" (骚扰电话), which authorities are actively working to curb.

"Do Not Originate" (DNO) Measures: China does not publicize a formal "DNO" list of numbers, but telecom authorities aggressively police caller ID spoofing and unauthorized call origination. The new Anti-Telecom Fraud Law (2022) mandates that carriers transmit true caller identification and block spoofed calls. For example, telecom operators must identify and intercept calls with falsified or "irregular" caller IDs, and for international calls they must clearly indicate the country of origin on the callee's display. It is forbidden to mask or fake caller identity—using devices or software to change caller ID or route VoIP calls into the public network without authorization is illegal. Certain number ranges are controlled: notably, numbers beginning with "95" (a special 8-digit prefix for call center and service hotlines) are tightly regulated. In mid-2020 MIIT explicitly banned call-center firms from using 95 short-code numbers for outbound marketing calls, after many spam callers misused these numbers. This effectively means 95XX numbers are "do not originate" for telemarketing – they are intended only for customer service or other approved uses. Organizations must use only the telephone numbers allocated to them and not pretend to be calling from government, emergency, or other protected numbers. Violations can lead to carriers terminating the number and regulators imposing fines or even criminal liability (if spoofing is used for fraud).

In summary, China's DNC approach is primarily consent-based: no unsolicited calls without permission. A formal opt-out registry is emerging via the "Refuse Call" platforms, and companies should ensure they integrate with these systems by honoring any "do not call" flags. They should also ensure all outbound calls carry a valid caller ID and originate through authorized channels – otherwise carriers will likely block them as spam or fraud.

Consent Requirements: Companies cannot simply buy or use phone lists and call people; they must have the individual's informed consent or another legitimate ground (such as necessity for a contract, legal obligation, public interest, etc.) to lawfully use someone's personal data (like their contact number). In practice, explicit consent is needed for telemarketing calls in almost all cases, since none of the other lawful bases typically apply to unsolicited marketing. Consent under PIPL must be voluntary, specific and informed – using pre-ticked boxes or implicit consent is not allowed. For "sensitive" personal information (e.g. someone's financial info, or possibly a call recording of one's voice which could be biometric), separate consent is required.

Transparency: PIPL mandates that individuals be notified about the collection and use of their data. Applied to call centers, this means companies should have a clear privacy policy or verbal notice explaining how they obtained someone's phone number and that it will be used for a marketing call. If calls are recorded, PIPL would treat the recording as personal data, so the caller should be informed. (Many businesses in China begin calls with a message like "This call may be recorded for quality purposes," to fulfill this notice obligation.)

Data Minimization and Security: The PIPL enshrines principles of necessity and data minimization – only collect data necessary for the purpose of the call. Outbound callers should not gather excessive personal details during calls without justification. Personal information collected through calls (e.g. call recordings, notes about the person) must be securely stored and protected under the Cybersecurity Law and PIPL's security requirements. Companies must prevent unauthorized access or leaks of call lists and recordings. China's Cybersecurity Law (2017) already required network operators to implement security measures and protect users' personal information, and the PIPL builds on this with more detailed requirements (for example, conducting personal information impact assessments for high-risk processing, appointing data protection officers for large-scale processors, etc.).

Retention and Use Limits: Under PIPL, personal data (like call recordings or phone numbers) should only be retained for as long as necessary to fulfill the purpose for which it was collected. If a consumer asks, companies must allow them to exercise their rights – e.g. to access or delete their personal data, or to withdraw consent to further calls. Using personal data from calls for a new purpose (beyond what was initially consented to) requires going back to the individual for additional consent.

Extraterritorial Reach: Notably, the PIPL applies not just to Chinese companies, but also to activities outside of China processing Chinese personal data. If a foreign call center handles personal information of people in China for the purpose of offering them services or products, or analyzing their behavior, the PIPL's provisions apply. In other words, an overseas company cold-calling Chinese consumers is expected to follow PIPL just as a local company would. Such foreign entities must also appoint a representative in China or establish an office in China to handle PIPL compliance, and register the representative's info with the authorities (per PIPL Article 53). This is akin to the GDPR's representative requirement for non-EU companies.

Data Localization and Cross-Border Transfers: China's laws impose constraints on transferring personal data abroad. The Cybersecurity Law (2017) and Data Security Law (DSL, 2021) require critical data to be stored in China, and the PIPL adds that large volumes of personal information or sensitive data may need a security assessment by CAC (Cyberspace Administration of China) before export. For a call center, this means if you are collecting Chinese citizens' data in China and sending it to an overseas server or foreign parent company (or having foreign agents access it), you may need to undergo official security reviews or use government-approved standard contracts for data export. If the call center is entirely abroad but calling into China, at minimum separate consent for cross-border data transfer should be obtained from individuals (PIPL requires telling people if their data will leave China).

Related Privacy Laws: In addition to PIPL, China's Civil Code (2021) establishes privacy as a personality right and could make egregious unsolicited calling a civil violation if it infringes someone's privacy or peace. The Consumer Rights Protection Law (CRPL) explicitly gives consumers rights over how their personal information is used – companies must keep consumer data confidential and use it only with consent, and they face fines for misuse. The E-Commerce Law and sectoral regulations (e.g. banking, telecom) also have rules on obtaining customer consent for marketing contacts. Furthermore, China's Advertising Law prohibits using electronic means (calls, SMS, email) to send advertisements to consumers without their consent or request – violating this can incur hefty penalties under the purview of the market regulators.

Enforcement: The Cyberspace Administration of China (CAC) is the primary data protection regulator (analogous to Europe's data protection authorities). CAC and relevant agencies have conducted crackdowns on misuse of personal data (for instance, apps that contact users without proper consent). PIPL violations carry fines up to ¥50 million or 5% of annual revenue, and serious violators can even be suspended or blacklisted. In the context of outbound calls, this means a company that, say, scraped a database of phone numbers and blasts calls without consent could be subject to investigations and punishment not only for the nuisance but for illegal handling of personal information.

Bottom line: Any outbound call program in China must be grounded in data privacy compliance. Companies should ensure they have a lawful basis (ideally express consent) to call each number, provide proper notices to individuals, safeguard call data, and honor any data subject requests (like "don't call me again" or deletion requests). These requirements mirror those in GDPR (consent, transparency, purpose limitation), reflecting how China's PIPL has created a GDPR-like regime for personal data. Both domestic and foreign entities contacting Chinese consumers are fully subject to these privacy laws.

Operating a call center in China (for outbound or inbound calls) triggers additional telecom-specific laws and administrative rules. These cover licensing, permitted activities, call practices (recording, caller ID), and conduct standards tailored to call center operations.

Telecom Licensing (Call Center License): In China, running a call center service is classified as a type of Value-Added Telecommunications Service (VATS). The Telecom Regulations of China require companies to obtain a VATS license for certain telecom-related business activities. Specifically, "Call Center Services" are categorized as B24 in the telecom service catalog. Companies that provide call center outsourcing services or operate call centers handling calls on behalf of others must hold a Call Center VATS License issued by MIIT or its provincial counterparts. This license ensures the business is registered and compliant with telecom rules. (If a company is just using phones internally to call its own customers, a separate license might not be needed; but any sizable call operation or third-party call service likely falls under this requirement.) Until recently, foreign investment in call centers was restricted, but as of 2025 pilot programs, foreign-owned enterprises can now apply for the B24 Call Center license in certain regions, reflecting a loosening of restrictions on foreign telecom service providers. All licensed call centers are subject to periodic oversight and must comply with the conditions of their license (e.g. using approved telecom resources and equipment).

Caller ID and Number Usage: Caller identification rules are strict. Call centers must use authorized numbers obtained from telecom operators for their outbound calls – e.g. a block of telephone numbers or a special short code (95xxxx). They are forbidden from transmitting a false Caller ID or masking their number. The Anti-Telecom Fraud Law (Art. 13) requires telecom carriers to enforce "real caller ID" transmission and block calls with spoofed or altered numbers. For international calls into China, carriers must indicate the correct country code or origin, and they will intercept any inbound call that tries to masquerade as a local number. For call centers, this means no spoofing techniques may be used – e.g. an overseas call center cannot legally make its call look like it's coming from a local "+86" number without going through an approved gateway. Likewise, 95-prefix short numbers (commonly used by call centers) are assigned by regulators and cannot be used for unauthorized purposes (as noted, MIIT banned using them for cold-call marketing). Call centers should work with telecom providers to ensure the outbound numbers they use are properly registered and labeled in caller ID databases.

Call Recording and Monitoring: It is common for call centers to record calls for quality assurance or training. Under Chinese law, call recording is allowed, but privacy laws require proper notice and consent in many cases. China is effectively a one-party consent jurisdiction for call recording – if one party to the call (e.g. the company) consents, it's generally not illegal to record. However, PIPL turns this into a transparency issue: recording a customer's voice is collecting personal information, so the customer should be informed. Best practice (and increasingly expected) is to play a pre-recorded notice at the start of the call or have the agent inform the person that the call is being recorded (and the purpose, such as "for service quality"). This ensures the individual's consent is at least implied by continuing the call. The content of recordings must only be used for the stated purposes and kept secure. Unannounced recording could potentially be deemed a violation of one's privacy, especially if the recording is misused. Additionally, State Secrets or sensitive information: If call centers deal with any government-related calls, recording might be subject to limitations under secrecy laws – though for normal commercial calls this isn't an issue.

Call Center Business Conduct: MIIT's "Notice on Strengthening Call Center Business Management" (2020) set out specific compliance requirements for call center operators. Key points include: Call centers must have internal controls to prevent and curb harassing calls, and are expressly prohibited from facilitating nuisance calls. For instance, a call center should not knowingly provide services to a client that uses the platform to spam-call random people. The notice to call centers in 2020 reiterated that they must not dial harassment calls or assist others in doing so. This places an onus on call center companies to vet their clients and monitor usage. If a call center platform is used to blast out large volumes of marketing robocalls without consent, MIIT can hold the platform accountable (not just the client).

Time Restrictions: Although not codified in a single law, regulators expect call centers to restrict calls to reasonable hours. Telemarketing calls in practice are usually limited to daytime/evening (e.g. 8am to 9pm) and not during individuals' rest hours. Persistently calling someone at night could be deemed harassment. MIIT's guidance to "regulate the time… of calls" signals that companies should set policies (for example, "do not call customers before 9am or after 9pm") to avoid complaints.

Frequency and Auto-Dialers: Auto-dialing equipment (power dialers or predictive dialers) can be used, but if they result in extremely high call attempts to the same number or a pattern of short, abandoned calls, it can trigger spam defenses. The 2020 draft regulation targeted "abnormally high-frequency calls" for blocking – implying that if a single number calls hundreds of users in a short time, or calls one user repeatedly, telecom networks may flag it. Call centers should impose throttling to prevent excessive call attempts and honor user requests to stop. Pure robocalls (pre-recorded messages) are generally not common or well-received in China, and sending them without consent would violate the same rules as SMS spam.

Consent for Calls: Beyond data privacy law, sectoral rules reinforce the consent requirement. For example, the Administrative Provisions on Communication Short Message and Voice Call Services (Draft, 2020) explicitly stated: "No organization or individual may send commercial SMS or make marketing calls to users without the user's consent or request, or if the user has explicitly refused. Lack of explicit consent shall be regarded as refusal." This draft (which is expected to be adopted to update older regulations) would cover voice call services similarly to how SMS is regulated. It also proposes that if a user does give consent and later revokes it, the caller must stop immediately. Call centers should obtain clear consent from targets (e.g. via a prior opt-in form or agreement), and also provide a quick way for people to opt out (such as pressing a key to be taken off the list or simply honoring verbal requests to "please don't call again").

Advertising Content and Other Laws: Call centers engaging in outbound sales must also comply with China's Advertising Law and other content regulations. Misleading or false statements during calls are illegal – for instance, making false promises, or impersonating government or bank officials to sell products is strictly prohibited (and could be fraud). Calls offering financial products may trigger oversight by financial regulators (CBIRC, CSRC, PBoC) particularly if they resemble illegal fundraising or scams. If calls are made to promote products, they should adhere to the content standards of advertising (e.g. proper disclaimers, no prohibited language). Call centers often have scripts vetted for compliance to ensure no violation of advertising, financial, or healthcare marketing rules. Additionally, consent for SMS follow-ups: if a call center plans to send an SMS after a call (like a link or promo code), that SMS is subject to the Administrative Provisions on Short Message Services, which require prior consent and an opt-out method in the message.

In essence, China expects call centers to operate under a licensed, tightly controlled framework – ensuring calls are made with consent, using proper caller IDs, at reasonable times, and not causing a public nuisance. Telecom authorities (MIIT) actively monitor call traffic with the help of carriers to spot and punish call centers that generate large volumes of complaints. Companies should integrate compliance into their call center operations by training agents on consent and polite practices, using technology to filter out calls to opted-out numbers, and cooperating with any telecom traceback inquiries (since MIIT can investigate which call center originated a harassing call). The regulations aim to balance the utility of call centers with consumer protection in an era where spam calls have been a top complaint of phone users.

Multiple government bodies in China oversee different aspects of outbound calling, from telecommunications management to consumer and data protection. Key regulators and their roles include:

Specialized Reporting Centers

A special mention is the 12321 Reporting Center, which is an initiative under the Internet Society of China with MIIT's backing. 12321 is the official spam and scam reporting hotline and website. Consumers can dial 12321 or use its website to report spam SMS and unsolicited calls. The center works with MIIT to investigate these complaints and can coordinate with carriers to blacklist numbers. While 12321 is not a law enforcement body per se, it's a key part of the regulatory ecosystem that companies should know. If a company's number is generating many complaints to 12321, MIIT and the carriers will quickly take notice. Portal: The 12321 website allows online submission of spam call evidence. Enterprises do not "deal" with 12321 proactively, but its existence means transgressions will be recorded and acted upon.

Other Authorities

Depending on the industry of the call, other regulators might have a say. For example, the People's Bank of China (PBOC) and the Banking and Insurance Regulatory Commission (CBIRC) oversee fair marketing of financial products – they expect banks and insurers to follow certain protocols in telemarketing (e.g. a bank cannot cold-call randomly to sell credit cards without consent, and must follow scripts for insurance cold-calls). The Ministry of Education (as seen in the 2018 joint action) cares if schools or education businesses leak student/parent phone numbers for telemarketing. The Ministry of Culture and Tourism might get involved if travel agencies make improper cold calls. In essence, China often uses a cross-departmental approach: MIIT handles the technical/telecom side, CAC handles data, SAMR handles consumer complaints, Public Security handles fraud, and specific sector regulators handle content and conduct in their domain.

Each of these authorities might have online portals or public databases that are useful. For instance, MIIT maintains a public inquiry system for valid telecom service licenses; SAMR has the National Enterprise Credit Information system where any administrative penalties (including for illegal telemarketing) against a company would be recorded for public view. Companies should identify which regulators apply to their calling activities and ensure compliance across the board.

Organizations making outbound calls in China must engage with certain official databases and registration systems to remain compliant. These include opt-out lists, numbering registries, and licensing systems. Below are key databases/portals and how companies interact with them:

"Refuse Call" Consent Registry: As noted, China is implementing a unified platform (谢绝来电平台) for consumers to register their telemarketing preferences. Telecom operators provide user-facing portals for this. For example, China Telecom's portal at donotcall.189.cn allows individuals to register their number and set preferences (opt in or out of marketing calls/SMS). China Mobile and China Unicom offer similar services (often via their mobile apps or by texting certain codes) to enroll in the do-not-disturb list. Companies need to respect these registries: a marketing caller should ideally query whether a number is on the "refusal" list before calling. While direct querying of the database by companies may not be open (for privacy reasons), the expectation is that telecom carriers will automatically filter out calls to numbers that have opted out. When setting up a new outbound number or campaign, businesses should coordinate with their telecom provider to ensure they receive updated DNC guidance. In practice, some large call centers integrate with carrier systems that return a signal if a user has blocked marketing calls, so the call can be dropped. The Refuse Call platform is nationwide, so once fully deployed, registration on one carrier's system should propagate to all carriers. How to register: Consumers sign up through carrier hotlines or websites. Companies don't register their own numbers on this list (unless they want to block inbound spam); instead, they must register to use the service if offered (some carriers might require telemarketers to formally agree to use a filtered dialing system). It's advisable for any company starting telemarketing to contact the major carriers for guidelines – they may be required to file their outbound number ranges and agree to scrubbing against the DNC list.

Telecom Numbering and Entity Database: MIIT has created a "telemarketing entity database" (主体库号码数据库) that contains the phone numbers and identities of legitimate organizations permitted to make marketing calls. This is essentially a whitelist of approved caller IDs. If a company obtains a special number (like a 95 or 400 number) for its call center, that number and the company's details are registered in this database. Telecom networks use it to distinguish known, authorized call sources from unknown ones. Registration: Usually, when a company gets a 95XXXX short code or a 400-number from MIIT/telecom operator, it is automatically added to the database. Companies using normal geographic phone numbers or mobile numbers for outbound calls might need to inform the carrier of those numbers' usage so they are tagged appropriately in systems. Being in the database is beneficial: calls from registered numbers can be monitored for compliance, but also not accidentally blocked as spoofed. Meanwhile, calls from numbers not in the database that show high-volume outbound activity will be flagged as "abnormal" and likely blocked. So, organizations must register their outbound calling numbers with the telecom provider/MIIT to ensure inclusion in the official database. This often happens during the process of obtaining a call center license or number assignment. It may involve providing the business license, the purpose of calls, and a promise to follow the rules.

12321 Complaint System: While not a registration, it's an important database of reports. Companies should be aware of the 12321 Spam Reports database. If a number accumulates complaints, it might end up on an industry blacklist accessible by carriers. Frequent offenders can have their number disconnected. There isn't a portal that telemarketers register for 12321 – instead, they monitor it. Some companies proactively check if their numbers are being reported (by inquiring with the carrier or using trial calls to see if flagged). If a company does get listed for spamming, they may need to coordinate with MIIT's 12321 center to remediate, e.g. submit proof of consent for their call lists or commit to corrective measures to have the number unblocked.

Call Center License Registration: To obtain a Call Center VATS License (B24), a company applies through the MIIT's online licensing system or at the local Communications Administration. The application involves registering company info, business scope, technical plans, and demonstrating a sound data security system. Once approved, the license details (company name, service type, license number) are recorded in MIIT's public database of telecom service providers. Where to register: The MIIT's Telecom Business Licensing portal (often a local e-government site) is used. For example, Beijing Communications Administration has an online application site for VATS licenses. Companies must renew or update their registration if details change. If operating across multiple provinces, a national (cross-region) license from MIIT in Beijing is needed. This licensing database is often consulted by other regulators to verify if a caller is a legitimate entity. Note: Recent pilot policies allow foreign-invested enterprises in certain zones to register for a call center license – they typically must set up a local subsidiary and then apply through the same channels.

Data Protection Officer and CAC filings: Large call center operations (especially those processing significant personal data) might have to register their Data Protection Officer (DPO) and data handling policies with authorities. The PIPL encourages organizations above certain thresholds to record their processing activities and possibly file these with CAC. If a call center is deemed a "critical information infrastructure operator" (unlikely unless it handles essential services) or processes a very large volume of personal info, it may need to undergo a cybersecurity review. For most telemarketing companies, this is not an immediate requirement, but appointing a person responsible for personal information protection and filing their contact with CAC is a compliance step (Article 52 of PIPL). There isn't a single national portal for this yet; often it's handled by CAC's local offices.

Public Security Real-Name Systems: All phone numbers in China (mobile or fixed) are subject to real-name registration with Public Security. Organizations that purchase large batches of SIM cards or phone lines for call centers must register those SIMs to the company's name and upload the user (company) identity info to the carrier's real-name system. If using IP phones or VoIP, those gateways also should be licensed. The Anti-Fraud Law requires sellers of phone SIMs or VoIP lines to verify the buyer's identity and usage. So effectively, the company itself is in a telco subscriber database tied to each number it uses. No separate action is needed other than providing credentials when getting the line, but the company should ensure it does not use any unregistered or "grey market" SIMs – that could lead to legal issues.

Industry-Specific Do-Not-Call Lists: In certain industries, regulators maintain their own do-not-contact lists. For example, the banking regulator (CBIRC) has instructed banks to honor customers' requests not to be called for cross-selling. Some cities or industry associations might have a self-regulatory DNC list (though these are not widely established). If your industry has such a list or opt-out platform, register with it to download or check against the numbers. For instance, in insurance telemarketing, an industry association might distribute a list of individuals who opted out of all member-company calls.

How/Where to Register Summary:

• For DNC: Through telecom operators – e.g. China Telecom's "Do-Not-Call" webpage (for consumers). Companies ensure integration by working with the operator.
• For Call Center License: Via MIIT's official licensing system (each province's Communications Administration site or MIIT's main site for cross-regional licenses).
• For Numbering: At the time of obtaining numbers from carriers/MIIT (forms will be provided by the operator).
• For Data (if needed): CAC's filing process (likely contacting local CAC office; in the future, possibly an e-platform if introduced).
• Complaint handling: 12321 hotline (no registration, just awareness and response if contacted).

Maintaining these registrations and consulting the databases is vital. Companies should periodically check for regulatory updates – for example, MIIT's announcement of the "谢绝来电" platform rollout, or CAC's updates on data processor registration – to ensure they sign up for any new compliance system. Proactively, firms can also train staff to use the 12321 complaint portal as a gauge of their performance: fewer complaints logged means they are likely in compliance with DNC expectations.

Extraterritorial Application of Law: China's Personal Information Protection Law explicitly applies to overseas companies handling Chinese personal data for offering products/services to people in China. This means a call center located, say, in the Philippines or India that is hired to cold-call individuals in China is expected to comply with PIPL (consent, data security, etc.) just as if it were in China. In practice, the overseas entity should obtain consent before calling (perhaps via an online sign-up from the person, or as part of a transaction) and protect any personal data (like the call recordings or phone lists) according to PIPL standards. They also should designate a representative within China to handle any inquiries from regulators, as required by PIPL. Failure to comply could result in the CAC placing the company on a blacklist, public naming, or coordinating with other countries' regulators – importantly, if the foreign company has any presence or partners in China, enforcement can be pursued via those channels.

Telecom Access for Foreign Calls: Technically, any call to a Chinese phone number from abroad must pass through China's international gateways (controlled by licensed Chinese telecom carriers). Chinese carriers, as noted, will flag international inbound calls and often prepend "International" or show the foreign number with a "+" on the receiver's phone, alerting users that it's from abroad. Foreign call centers might find pickup rates low because Chinese users are wary of scam calls from overseas (a lot of fraud historically originated from foreign call centers). Some foreign companies try to use local China numbers to call (to appear domestic), but doing so typically requires partnering with a Chinese telco or VoIP provider. Using an internet dialing solution that injects a local caller ID without authorization is illegal in China. Thus, a foreign firm cannot simply spoof a Beijing number to call from London – that would be blocked and violate Chinese law.

Options for Compliant Operation:

Option 1: Local Presence. Because of these hurdles, many foreign businesses choose to set up a local call center or contract with a China-based call center to legally call Chinese customers. With a local presence, they can get a proper license and local numbers, ensuring compliance. China has even opened up call center VATS licenses in some regions to wholly foreign-owned subsidiaries, making it easier for an overseas company to establish a compliant call center operation onshore.

Option 2: Cross-Border Calling. If a foreign company still calls from abroad, it should use official international dialing. This means getting a telephony service that routes via China's authorized carriers (e.g., renting an international toll-free or a "+86 10 xxxx" number from China Telecom's international division). In such cases, the company's calls will show a proper number (possibly a Hong Kong or overseas number). The company must ensure it has documented consent from the people it calls, since enforcement for DNC violations could be tricky but not impossible: Chinese authorities could, for example, block all calls from a certain foreign number if it's found spamming users, or even reach out through diplomatic or law enforcement channels if serious (the Anti-Fraud Law asserts jurisdiction over foreign perpetrators of telecom fraud against Chinese citizens).

Enforcement and Liability: If a foreign entity violates these rules (say it conducts massive unsolicited calling without consent), what can Chinese regulators do? Several things:

• Blacklist and Block: MIIT can instruct carriers to block calls originating from certain sources. For example, if a particular foreign VoIP gateway is blasting spam calls, Chinese carriers can drop traffic from that gateway. This network-level enforcement is a strong deterrent – it could cut off a foreign call center's access to Chinese users entirely.
• Punitive Measures in China: Should the foreign company have any assets, offices, or clients in China, regulators can impose fines on those or even detain responsible personnel if Chinese law is broken. PIPL allows China to impose fines on overseas violators and potentially restrict or ban a violating company's business in China (they could be deemed "untrustworthy" and have any data transactions with China cut off).
• Collaboration with Other Countries: China may also seek cooperation under international frameworks if the activity is severe (especially if it edges into fraud). This is more likely for scam calls than pure marketing, but it's worth noting.

Practical Compliance Tips for Foreign Callers:

• Follow Chinese standards for consent and content. Even if you are not physically in China, align your practices with PIPL and CRPL. For instance, maintain records of how each phone number on your list gave consent (and be prepared to show that if questioned). Provide a Chinese-language privacy notice to users.
• Provide Opt-out Mechanisms: During a call, if the callee says "I'm not interested" or "不要再打给我" ("don't call me again"), that should be treated as an opt-out. Do not call that person again – failing to respect such requests would violate Chinese consumer rights laws and could lead to complaints.
• Local Representative: Designate a contact person in China (could be a legal representative or a compliance consultant) to interface with regulators. This person's details should ideally be filed with CAC to meet PIPL requirements.
• Consider Time Zones: A foreign call center must also be mindful of the time difference – calling Chinese users at 3 AM their time will certainly cause backlash and likely complaints.
• Understand Cultural and Legal Sensitivities: Certain topics are regulated – e.g., you cannot mention gambling or political content in calls, and you should be careful when referencing personal information (due to privacy). Ensure your scripts are compliant with Chinese advertising and consumer protection law (no false claims, no harassment).

E-Commerce and Cross-Border Marketing: If the calls are part of a broader business (like a foreign e-commerce site marketing to Chinese consumers), note that Chinese e-commerce law might also impose requirements when targeting Chinese consumers (such as fair marketing and not infringing consumer rights). If goods or services are sold, consumer protection laws would allow Chinese consumers to seek remedies in China even if the seller is abroad.

In summary, foreign companies are not beyond the reach of Chinese outbound call regulations. They must essentially follow the same rules: get consent, honor do-not-call wishes, use proper caller ID, and protect personal data. The difference is that compliance is largely voluntary until an issue arises, but given China's heightened focus on data sovereignty and scam prevention, the net is tightening on overseas calling. Many savvy foreign firms choose to partner with Chinese call centers or use cloud call services that are compliant, rather than take risks. If you are a foreign company planning to telemarket in China, it's wise to consult legal counsel and possibly work through a licensed local entity to ensure all regulatory bases are covered.