Governing the Data Layer: China’s Digital Logistics Infrastructure and Europe’s Visibility Gap

Abstract

Policy recommendations The following recommendations address the governance gap that opens when global value chains are coordinated through data infrastructure that Europe uses but does not control. They move from recognition of the problem to the instruments already available within the current EU agenda. • Treat logistics data infrastructure as critical infrastructure. The platforms and standards carrying information about goods flows should enter EU resilience and economic-security reviews on the same footing as ports, pipelines and networks. A dependency in the data layer is a dependency, even when no asset changes hands. • Screen data-layer agreements at European ports. The Ports Strategy commits the Commission to criteria and guidance on foreign ownership and control of ports identified as strategic dual-use infrastructure. That guidance should cover data and software agreements, not only equity stakes. Memoranda between EU ports and foreign state-run logistics platforms are today concluded port by port, with no European overview of what flow data leaves the Union. • Deliver eFTI as one European capability, not 27 national silos. From 9 July 2027 member state authorities must accept electronic freight transport information, and implementation is proceeding through national gates built separately. Without binding interoperability across them, Europe will digitise paper without gaining a shared view of its own flows. • Bring the transport-chain data guidelines forward, and give them binding force. The Ports Strategy promises EU guidelines for data sharing in the transport chain by 2028 — a year after the eFTI obligation begins. Reversing that sequence, and connecting eFTI gates, the maritime single window and the customs data hub in a federated architecture, would give European authorities and firms a symmetric view of flows. Federation, not centralisation, is the design lesson of the failed private platforms, and the Ports Strategy concedes it. • Attach flow-data obligations to the customs reform. Removing the EUR 150 exemption and imposing the interim duty address revenue. Access to shipment-level data from non-EU e-commerce platforms should be secured in the same reform, while the customs data hub is still being designed ahead of its arrival in mid-2028. • Monitor China’s logistics-data standardisation systematically. LOGINK’s international agreements, its contribution to an ISO standard for visibility data interchange between logistics information service providers, and China’s wider standards diplomacy in transport data deserve the foresight attention the EU now gives to AI governance and technical standards.