The letter was sent in response to a request for public comments on the draft amendments from the Chinese State Council Information Office and the MIIT. NFTC Vice President for Global Trade Issues Jake Colvin and SIIA Vice President for Public Policy Mark MacCarthy wrote:
“This proposal would impose an enhanced regulatory regime without adequate safeguards to ensure the fair application and administration of rules. … Transparent procedures and appeals processes are essential to ensure that internet policies are applied evenly to domestic and foreign entities and do not unfairly limit online channels for trade or marketing or otherwise discriminate against commercial activities by global providers.
“… A recent survey from the Boston Consulting Group found that Chinese small and medium sized businesses that used the internet intensively grew their sales by an average of 25 percent, compared to 9 percent growth for firms that used the internet less intensively or not at all. The effect of these regulations would be to limit the growth and use of the internet in China, thereby discouraging local innovation, business productivity, and economic development.
“…[W]e urge the reconsideration of the proposed revisions to the Internet Information Service Management Rules. Future internet policies should be predicated on transparent, fair, and predictable treatment of individuals and entities, and should encourage local innovation and
creativity while ensuring the equitable treatment of global businesses.”