Article 38(3) of the Personal Information Protection Law establishes the principle of equivalent protection for crossborder transfers of personal information, requiring that personal information transferred abroad continue to receive protection no lower than that provided within China. In theory, this principle functions as a regulatory “gatekeeper” for controlling outbound data fl ows. However, unlike its widespread recognition and consistent application in the European Union, the principle has largely remained dormant and underutilized in Chinese practice. At the surface level, this predicament is attributable to the high costs and practical diffi culties arising from legislative defi ciencies in assessing third-country personal information protection regimes and in defi ning appropriate protection standards. At a deeper level, the divergence refl ects fundamental diff erences between the EU and China in their strategic objectives in the context of global digital competition. To revitalize the principle of equivalent protection in China, it is necessary, on the one hand, to operate within the existing institutional framework by optimizing the allocation of assessment responsibilities and establishing reasonable assessment benchmarks to address current institutional shortcomings. On the other hand, it is also essential to explore regulatory sandboxes, introduce additional exemption clauses, and conduct ruleof-law pilot programs in free trade zones, thereby building a normative reserve for the application of the principle of equivalent protection across diff erent scenarios.