Regulating AI in a Fragmented World: The Diverging Paths of the EU and China and Their Impact on Global Governance

  • 06 30, 2025
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  • Author:Xuan Li, Xing Li
 Abstract

This study examines the contrasting AI regulatory frameworks of the European Union (EU) and China, shaped by their distinct political cultures and strategic objectives. The EU adopts a rights-oriented, risk-based model, categorising AI systems based on their potential impact on civil liberties. Conversely, China employs a sector-specific, security-driven model that emphasizes national security, social stability, and economic growth. The findings highlight three key differences: (1) Regulatory Philosophy: The EU prioritises rights protection, while China focuses on security and technological competitiveness. (2) Focus and Approach: The EU uses a universal risk-based model, while China tailors regulations to specific sectors. (3) Key Characteristics: The EU mandates explainability and accountability, while China prioritizes data labelling and content control. In conclusion, the EU envisions AI as an extension of its human rights-first philosophy, constrained by legal and ethical frameworks. China, by contrast, views AI as a tool for industrial and geopolitical dominance, driving what may be termed “AI-facilitated reindustrialization.” While global AI governance convergence is unlikely, pragmatic adaptation and mutual recognition of differing norms could facilitate cooperation.

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