Abstract: This article explores how China is developing a unique location-based data outbound deregulation regime to mitigate the negative effects of its initial security-driven regulations by repurposing free trade zones with data outbound negative lists. Using an infrastructural-thinking framework, this article examines the evolution of data outbound regulation in China, recent initiatives in the country’s free trade zones, and the dynamics between local and central governments. China’s data outbound practices are enabled and constrained by its global ICT infrastructural connectivity and domestic ICT distribution. Free trade zones become appealing deregulation testing grounds due to their overlap with critical ICT hub locations and their long-standing role as sites for policy experimentation. The ongoing pilot projects, through the interplay of law and infrastructure, present promising potential to channel China’s data outbound activities into specific areas, thereby increasing their visibility, making them more amenable to regulation, and fostering both local and national economies.

Keywords: Data Outbound Regulation; Digital Infrastructure; Policy Experimentation; Free Trade Zones; Digital Economy; Data Flow