Determining the Future of the Internet: The U.S.-China Divergence
- Both the U.S. and Chinese governments put their “values” at the forefront when determining their digital policy frameworks and promoting their visions internationally. The major U.S. value at play is individual autonomy, especially as it applies to freedom of speech; in China, it is collective order.
- American priorities for cyberspace are focused on supporting an ambiguous concept of digital freedom, mirroring the rights and rhetoric that dominate American political culture.
- Regulatory agencies such as the Cyberspace Administration of China help the Chinese government keep a tight rein on the Chinese internet, overseeing platform regulations, algorithmic recommendations, speech control, and campaigns aimed at developing popular support for the policies of the Chinese Community Party (CCP).
- Culture, like the internet, is viewed by Chinese officials as full of potential — as well as threats. Therefore, the CCP attempts to manage manifestations of what it deems acceptable Chinese culture, both offline and online.
- China under Xi Jinping is attempting to weave extreme internet regulation — the maintenance of a separate Chinese internet — into other major CCP priorities, such as the socialist core values (social, moral, and legal guidelines) and Xi’s common prosperity agenda. The “Clear and Bright” Qinglang 晴朗 campaign is a key example of a campaign-style push for digital control.
- Xi is intent on promoting “internet sovereignty” as a revised global norm. Current efforts are focused on cultivating international tolerance of the concept of internet sovereignty, which is in opposition to the concept of a free and open internet, as envisaged by its Western inventors.
- Maintaining control of the domestic internet is a bigger priority for the CCP than influencing the global internet(s), for now.
- Rising tensions between the United States and China and increasingly sharp lines of division between the two superpowers’ values, as they apply to both international governance and digital policy, are coming into sharper focus as the internet continues to gain economic and social prominence.
When protests broke out in China in response to severe, and sometimes fatal, COVID-19 lockdowns, blank sheets of A4 paper became the dominant symbol of dissent, appearing in the streets of Chinese cities and at solidarity protests around the world. Their digital analog, a visual rendering of a white square (akin to the solid black square used by the #BlackLivesMatter movement), came to represent protests against not just China’s zero-COVID policy but the Chinese government’s speech control regime; the white square was, at least temporarily, a censor-proof anti-censorship symbol. The square’s blankness cultivated versatility: Each individual could fill it with their own unwritten objections. This creative, evasive, multipurpose tool is representative of efforts to resist China’s tightening online discourse environment. The 2023 New Year celebration campaign of the Cyberspace Administration of China (CAC), which asked netizens to submit online examples of “positive energy” (正能量) throughout 2022 — an arduous year in which millions of Chinese faced lockdowns — belied an intentional reluctance to read the room.
While its implementation has been far from seamless, speech control in China should not be understood as the ad hoc impulses of aggrieved authorities. In times of crisis, repression can be reactive. But, unlike less advanced censorship regimes elsewhere in the world, Chinese censorship is not limited to reactivity. Its ultimate ambition, intended to unfold in the coming decades, is to implement a grand strategy for creating, guiding, and rewarding online discourse that is favorable to the leadership and legitimacy of the Chinese Communist Party (CCP). To achieve such an ambitious goal, censorship is insufficient. The Chinese government is also cultivating an internet that offers a deluge of “positive energy” that is free from “harmful information,” supportive of the government, and capable of fostering economic growth. Recent technology policy documents, such as the State Council’s white paper titled “Jointly Build a Shared Future in Cyberspace,” frame the discussion of values on the internet in terms that are conspicuously amenable to CCP rule: “Cyberspace, like the real world, values both freedom and order. Freedom is the purpose of order, and order is the guarantee of freedom.”
China’s highly empowered CAC is one of the principal agencies tasked with reaching these objectives. In a comprehensive analysis of the CAC’s form and function, Jamie Horsley of the Paul Tsai China Center at Yale Law School describes its uniquely broad authority: “The CAC … enjoys potential jurisdiction as a supra-ministerial regulator over virtually all state and private sectors touched by nearly ubiquitous online activity.” A merged party-state organ, the CAC’s original mission to police online content has been elevated to include regulation of cybersecurity, data security, and privacy.
The United States lacks a CAC equivalent. Rather than getting too involved in the messy process of trying to pass legislation on digital regulation, President Joe Biden’s administration has focused on injecting a broad vision of American values into the discourse regarding the global internet. Unsurprisingly, these values run contrary to China’s internet regulations, and they appear to be at least partly a response to the restricted internet environment of America’s biggest economic competitor. In 2022, the Biden administration released the Declaration for the Future of the Internet (DFI), which was signed by more than 60 countries, most of them democracies. The DFI implicitly counters China's domestic and international digital development efforts and argues for a “global internet” and free flow of information. The White House’s Blueprint for an Artificial Intelligence (AI) Bill of Rights similarly aims to ensure that the use of AI does not unravel “democratic values, foundational American principles that President Biden has affirmed as a cornerstone of his administration.”
Both countries put values and domestic conditions at the forefront of their technology policies, which have broad implications beyond their borders. The United States hopes to attract partners and allies to join its freedom-forward vision of the internet, in which firewalls like China’s would become untenable. Officially, U.S. government officials champion an internet where all users have the freedom to engage with each other openly, share ideas, make money, and, in an unexplained utopian workaround, avoid excessive surveillance by both business and government.
America’s posturing on internet regulation takes place amid a fierce domestic debate about how regulators and platforms can and should handle misinformation, disinformation, and hate speech. Meanwhile, further risking claims of hypocrisy, the U.S. government criticizes authoritarian states’ use of digital surveillance while law enforcement agencies such as the New York Police Department continue to use facial recognition data to arrest suspects. As Josh Chin and Liza Lin describe in their book Surveillance State, public sentiment against privacy violations inspires U.S. law enforcement agencies to use facial recognition secretively, often in ways that transcend their original, admitted purpose. “In a sense,” they write, “New York City’s entire surveillance apparatus was an example of mission creep.”
Chinese officials, meanwhile, advocate for “internet sovereignty” (网络主权) and argue that every country should be able to govern its internet as it sees fit. In China, the government uses its technological capacity to simultaneously provide controlled convenience to speed up economic growth, sometimes offering meaningful employment and other opportunities to individuals, and curtail personal and societal freedoms. As in many areas of Chinese governance, internet regulations in the People’s Republic of China (PRC) are rhetorically resolute and experimental in application, nationally endorsed and locally targeted, and, at the individual level, helpful to some and destructive to others.
At 39 years old, the internet is on the brink of middle age. Yet, rather than try to understand how engaging with the internet has affected and continues to shape human brains and the interests they pursue — or even are aware of — corporate and consumer interest lies more in fostering its future iterations (like the metaverse). Our reliance on digital tools only continues to grow, rendering the divide between online and offline life increasingly fungible even as individuals still lack basic protections from surveillance and, in countries like China, state censorship and digital repression. Government authorities in the United States and China have responded to this shared quandary with unsurprising distinction.
The CCP’s Case for Cyber Culture
At the 2022 China Internet Civilization Conference, officials made the case that moral fortitude should characterize China’s online environment. According to CAC Deputy Director Sheng Ronghua, “Online propaganda continues to be deep and real” (网上宣传持续走深走实). Sheng argued for pushing forward the CCP’s theories of innovation so that they enter people’s hearts and minds, carefully conducting online propaganda on major topics, and constantly improving whole-of-society network security.1 Other coverage of the conference mentioned officials’ aim to “allow advanced culture and the spirit of the times fill cyberspace”2 and promote “network civilization.”3
“Propaganda,” “security,” and “civilization” are all loaded terms. From the party’s perspective, they refer to officials’ ability to control and disseminate “correct” information, “protect” Chinese netizens from the online threats posed by corporate interests and foreign content, and elevate “correct” understandings of China’s culture and history, respectively. The State Council’s 2022 white paper also implies a correlation between cultural progress — and control — and technological advancement: “We must accelerate the deep integration of culture and science and technology, better build an advanced socialist culture with advanced and applicable technologies, reshape the mode of cultural production and dissemination, and seize the commanding heights of cultural innovation and development.” Seizing those heights requires pairing modern technologies with “advanced socialist culture” — a term that packs repressive one-party governance into its selective understanding of Chinese traditions.
Culture, from the CCP’s perspective, must be modulated by the state to meet the technological moment. According to the 14th Five Year Plan for Cultural Development Planning (English translation available here), released in August 2022, “in order to meet the new wave of scientific and technological revolution … We must accelerate the deep integration of culture and science and technology, better build advanced socialist culture with advanced and applicable technology, reshape the way of cultural production and dissemination, and seize the high ground of cultural innovation and development.”4 Technology is central to the propagation of “culture.” Centering this claim on meeting the “new wave” of technological revolution assumes a continuance of the technological revolutions that the PRC pursued in previous decades and heightens the urgency of this proposed integration: There is limited time to ensure that (correct) culture is used to guide technological development.
The plan is both a declaration of what needs to be done and a celebration of what has already been achieved. “The core socialist values and excellent traditional Chinese culture have been widely promoted, mainstream public opinion has been continuously consolidated and strengthened, cyberspace has become increasingly clear, and the spirit of the people of all ethnic groups across the country has become more energetic.”5
Integrating the assertion that “cyberspace has become increasingly clear” (code for increasingly free of dissent and full of “positive” content) alongside such fundamental and wide-reaching claims for cultural cohesion and “success” elevates the import of not just a highly censored internet, but one that is “clear and bright” (晴朗). Cultivating a “clear and bright” cyberspace is framed as an essential component of the project of defining and disseminating CCP marketing on what constitutes online expressions of Chinese culture.
In the 14th Five Year Plan, Chinese Marxism is a driving force; one goal for the period ahead is to achieve “a new leap in the Sinicization of Marxism.” Culture, according the plan, can be crafted to help achieve existing goals. “To conform to the historical changes in the main contradictions of our society, to meet the people's growing needs for a better life, and to promote the all-round development of people, culture is an important factor.” Culture is conveniently vague, but surely it includes much of what is shared, found, and purchased online. The use of the term “main” or “principal contradictions” suggests the need for culture to bend to the present needs that China’s leaders have identified as essential to the country’s future development.
Under Mao, the principal contradiction was between the proletariat and the bourgeoisie; under Deng Xiaoping, it was “the ever growing material and cultural needs of the people versus backward social production”; under Xi Jinping, it is between “unbalanced and inadequate development and the people’s ever-growing need for a better life.” Culture is consistently the sister of material; these two are paired in a way that may appear idiosyncratic but perfectly reflects the party-state’s logic, in which economic growth corresponds to China getting closer to living up to its full civilizational potential: national rejuvenation.
Technological advancement is too important to regulate retroactively. Technology is representative of the party’s success in cultivating not just China’s but Chinese economic and cultural development. It is thus both prized and kept on a very short leash.
How the “Clear and Bright” Cyberspace Campaign Mirrors Xi-Era Priorities
The “Jointly Building a Shared Future in Cyberspace” white paper has separate sections for the global internet and China’s internet; the separation reflects the PRC’s preference for internet sovereignty. China’s “new development stage” and “new development philosophy” explain why the ideal time for China to develop its digital “strength” is now.
The white paper frames this opportunity for promoting the qinglang (晴朗) campaign as the outcome of hard-fought goals. An unchecked internet would have left China’s netizens at the mercy of malign actors and evil corporate interests. Luckily, according to this narrative, the government stepped in. It frames the cleansing of cyberspace as a public service: “A clean and sound cyber environment is in the interests of the people, whereas a polluted and degenerate one is against the public interests.” But the paper goes beyond sanitation, linking China’s information-control efforts to state-led morality: “China is committed to creating a healthy, civilized, clean and righteous cyber ecosystem.”
The State Council’s white paper celebrates what qinglang has achieved: “China has launched a campaign to rectify the disorder in cyberspace ... It has tightened regulation, taken rigorous action against online activities that violate the law and regulations, and striven to rein in chaotic fandom culture.” Qinglang is placed in a section titled “Development and management of the internet in China,” since such a comprehensive effort is not possible globally, and even if it were, any international iteration would fail to ground digital regulation in the CCP’s version of Chinese values.
On top of central government directives, regular people who feel so inclined can help realize the party’s vision for a “clear and bright” cyberspace. Netizens have been notified that they are free to tattle on others for spreading “rumors” or harmful information on the internet. Netizens are also invited to “rat out” others for propagating “historical nihilism” — the party’s term for depictions or mentions of histories it would prefer to suppress. These overtures suggest that authorities believe a degree of public buy-in is necessary to sanitize cyberspace and create an internet that meets their governance needs.
In 2021, the CAC released a directive requiring internet companies to disclose information about the technology and algorithms behind their platforms — the first time a regulator has ever taken this step (English translation available here). In an analysis of the instruction manual for compliance, Matt Sheehan and Sharon Du show that it “reveals significant new disclosures that do not show up in the public versions of the filings.” In addition, the directive opens by declaring it functions to promote “socialist core values”6 or SCVs.
Official Chinese conceptions of righteousness are tied up in the CCP’s socialist core values, which appear on propaganda posters and must be considered by Chinese app developers, technology regulators, and censors, among others. Per the revised “Provisions on the Administration of Mobile Internet Applications Information Services,” released in June 2022, app companies are instructed to “adhere to the correct political direction”7 and to “enhance core socialist values.” These values are prosperity, democracy, civility, and harmony (at the national level); freedom, equality, justice, and rule of law (at the societal level); and patriotism, dedication, integrity, and friendship (at the individual level).
While each value can be interrogated individually, all of them are designed to promote the CCP’s unquestioned authority over all aspects of life and morality in China. In their article “Creating a Virtuous Leviathan: The Party, Law, and Socialist Core Values,” Delia Lin and Susan Trevaskes lay out the stakes that such moral paternalism poses for party legitimacy:
The integration of Socialist Core Values into socialist rule of law legitimates the moral authority of the almighty Party. In addition, the inclusion of democracy, fairness, and freedom in the Socialist Core Values suggests the Party considers that these values are not the exclusive hallmark of a liberal democracy. The assertion here is that the CCP is capable of building a comprehensive value system by offering an alternative to the so-called universal values as proclaimed by the West. This requires establishing the moral legitimacy of an authoritarian “China Model” as an alternative to liberal democracy.
SCVs are not just propaganda; they have been integrated into China’s legal system. A 2016 document titled “Guiding Opinions on Further Integrating Socialist Core Values into the Construction of Rule of Law” stipulates that all laws and public policies be executed in a way that “guides the correct value orientation in society.” The Central Committee’s 2018 plan on “Integrating Socialist Core Values into the Legislative Amendment Plan for the Construction of the Rule of Law” promotes the total integration of socialist core values into China’s legal system within 5 to 10 years. In 2021, the Supreme People’s Court released its “Guiding Opinions on Deeply Promoting the Integration of Socialist Core Values into the Analysis and Reasoning of Adjudicative Instruments,” which gave judges guidance on how to implement SCVs in their rulings.
That legal integration has a digital component. According to a question-and-answer transcript about the 2018 announcement, “The plan will emphasize the online dissemination of socialist core values … and promote the realization of a healthy, positive, and forward-looking internet.”
Healthy, not harmful; clear, not polluted; sound, not chaotic; positive, not negative: From the CCP’s perspective, these guidelines are the foundation of China’s internet development. These dichotomies betray the party’s torn attitude when it comes to digital regulations: When China’s leaders look at the internet, they see no limit to its possibilities — or its threats. That tension has come to characterize Xi’s concurrent enthusiasm for China’s technological development and aspects of his common prosperity agenda that rein in big business (especially tech firms), limit the amount of time that minors can spend playing video games, and crack down on online fan communities, all while promoting the development of healthy and profitable digital culture.
Chinese netizens are not necessarily eager to heed the CAC’s encouragement that they spread “positive energy” and “socialist core values.” Online discourse at times displays sarcasm, humor, and, despite regulators’ and censors’ best efforts, personal discontent and direct criticism of the regime. These trends do not exactly follow authorities’ conception of a “clear and bright” cyberspace. Moments of domestic chaos or turmoil in which censors appeared paralyzed — such as the initial coronavirus outbreak in early 2020 or the November 2022 anti–zero-COVID protests, which occurred both online and offline — demonstrate that behind every censored post is a human who has to wait for orders to come before they can attempt to enforce them.
Xi’s obsession with national strength includes short-term interest in one-upping the United States, China’s major competitor, as well as the longer-term goal of achieving “national rejuvenation” — which will be, conveniently, both out of reach and relevant for the rest of Xi’s life. Moral purity is a major tenet of Xi’s plans for China’s rise, exhibited in his characterizations of the “China dream” that permeates the state’s policing of public discourse online and offline. The qinglang campaign, socialist core values, common prosperity, and other party propaganda pushes provide a redundant and mutually reinforcing blueprint for the CCP’s intentions when it comes to internet governance. Taken together, they have proved to be usefully multipurpose in migrating defense of the party’s offline “values” online.
“While the DFI isn’t by its nature a binding treaty, it is evident who is signed up to [it] and who isn’t.” Tim Wu, former Special Assistant to the President for Technology and Competition Policy, said at an event last year hosted by the Asia Society Policy Institute in New York. “We think that the goal is the sending of signals by countries as to where they stand and what kind of principles they’re going to stand up for,” he continued. As in China, values define America’s pitch for its vision of a global internet.
American priorities for cyberspace have less to do with easing disorder and more to do with nurturing a vague, if promising, concept of digital protections modeled on the rights embedded in the U.S. constitution — and body politic. Relevant declarations prepared by the Biden administration read more as vision boards than authoritative policy documents, a reflection of the relatively loose internet regulatory environment in America.
A series of “should” statements with ambiguous or no authority, the Blueprint for an AI Bill of Rights seeks to defend freedom, democracy, and privacy. The other key document that the White House has released in this area, the Declaration for the Future of the Internet, is massive in scope and lofty in moral fortitude.
The AI Bill of Rights is decidedly focused on the personal rights of individuals: “You and your communities should be free from unchecked surveillance,” it suggests, adding that surveillance technologies “should” be subject to “heightened” evaluation regarding their potential to do harm. The use of “you” is indicative of the authors’ focus on the individual — a characteristic of Western understandings of human rights — and provides a stark contrast with China’s ecosystem-driven visions for cleaning and clearing cyberspace. The jab at “unchecked surveillance” can be read as a critique of tech-enabled authoritarianism, corporate data greediness, or both — though official U.S. statements on this issue are careful to avoid direct criticism of the business community. The DFI, for example, seeks to “realize the benefits of data free flows with trust based on our shared values as like-minded, democratic, open and outward looking partners.”
Though it does not propose solutions to them, the AI Bill of Rights mentions some of the serious issues posed by emerging technologies: “Automated systems should be developed with consultation from diverse communities, stakeholders, and domain experts to identify concerns, risks, and potential impacts of the system,” it advises. This suggestion, paired with the declaration that “algorithms used in hiring and credit decisions have been found to reflect and reproduce existing unwanted inequities or embed new harmful bias and discrimination,” suggests that the administration intends to correct some of the major issues that those concerned about AI ethics have been flagging for years.
The DFI is similarly aspirational. “We call for a new Declaration for the Future of the Internet that includes all partners who actively support a future for the Internet that is open, free, global, interoperable, reliable, and secure.” This language puts “security” on the same level as “global” — a strong contrast with the Chinese State Council’s white paper on cyberspace and its delineation of a separate section for China’s internet. That said, as Alex Enger of the Brookings Institution has argued, the Biden administration likely is not trying to influence China (or Russia) but instead aiming to attract countries with unstable democracies and states that have made repressive moves on the internet but have not constructed a comprehensive system of digital authoritarianism.
The European Union’s General Data Protection Regulation (GDPR) differs from the U.S. approach in its specificity and enforceability; it differs from the Chinese approach in that it grants “rights” to the data holder and ensures transparency. The regulation, which went into effect in 2018, has been successful in that it takes individual control over personal data seriously. It stipulates, among other things, that companies, governments, and other organizations must obtain clear consent before collecting personal data; places protections on “sensitive” information like race, gender, and political affiliation; and requires that companies treat location data and other identifiers as personal data.
The United States’ and China’s real and imagined “values” inform each country’s approach to regulating and shaping the future of the internet. The right to privacy, an American ethos, is the power to be detached from a powerful big brother — namely, the government. This government-focused framing gives lenience to corporations who are notorious for snooping and for business models constructed on surveillance and the eerily effective predictive capacity that it engenders. If this version wins, it is easy to imagine a global internet that takes corporate bottom lines as its priority and individuals’ free speech as its secondary, albeit frequently touted, concern.
In China’s highly censorious digital and analog discourse environment, the burden of rhetorical resilience falls on the people. They see what they see, imagine what they cannot, discuss what they find, tolerate what they cannot avoid, and, despite the risks, protest when they feel they must. The algorithms and regulations tailored to China’s fenced-in internet produce and streamline more than enough information to keep 1.4 billion minds occupied — but not fooled. As long as comprehensive and uncontested acceptance of the CCP’s rule is out of reach, true “internet sovereignty” will likely remain elusive.
Another of the DFI’s “should” statements reads, “The Internet should operate as a single, decentralized network of networks — with global reach and governed through the multistakeholder approach.” As long as China is part of the world and the CCP is in power, it will be difficult to rewind the clock to a time when a single internet might have been possible. The Chinese government has no motivation to tear down its Great Firewall or adhere to a rulebook rooted in international human rights norms. Considering this reality, the United States might distinguish more directly between the internet that it participates in — the free one — and China’s internet, which is populated by netizens who have minimal chance of accessing the open “network of networks” they envision. For better or worse, a separate, dynamic Chinese internet exists. Chinese regulations have succeeded in crafting an online environment that adheres to CCP laws, regulations, and repression. However, despite the party’s claims, this compliance by no means constitutes a comprehensive representation of Chinese culture.
Future papers in this series will cover other areas of technological development and governance that the United States and China are pursuing with characteristic contrast. These topics include “innovation” and the degree to which the state should be involved in fostering it, as well as the complex supply chain politics surrounding key technologies like semiconductors. This series will also consider the Sinophone internet without PRC governance, as it exists in places such as Taiwan and diverse Chinese-speaking diaspora communities. It will also engage with surveillance strategies and methods by which PRC authorities pursue constant and ubiquitous monitoring of Chinese citizens. Lastly, it will examine what, if any, positive outcomes China’s unique digital regulations offer, including the PRC’s efforts to temper dangerous AI capacities such as deepfakes.
In many ways, the two countries’ approaches to digital governance reflect their real-life ethos and regime types. But even the most deeply ingrained governance instincts are tested by the internet, an inherently unpredictable and limitless resource whose power was not the purview of previous generations of leaders. Instead of rallying around the common challenges presented by new technologies, the United States and China appear more likely to insert every new digital development into their shared framework of immersive competition.