It's not an exact Ctrl+C, Ctrl+V of the USMCA digital trade chapter -- but it's pretty close.
Compare here:
bit.ly/2LoV2xN
US approach (below) is v. broad.
The EU defines personal data privacy as a “fundamental right” & allows governments to take any action to protect personal data & privacy.
EU text: bit.ly/2vJRw6F
It may very well be impossible to reconcile the yawning differences between the Chinese and Western approach to the digital sector.
I mean, China says the talks shouldn't even cover data flows. 💣