Converging Proposals for Platform Regulation in China, the EU and the U.S : Comparison and Commentary

China's State Administration for Market Regulation in China announced two guidelines in October 2021. The drafted Guidelines for Classification and Grading of Internet Platforms (互联网平台分类分级指南) (“Classification Guidelines”) categorize digital platforms into super, large and medium-to-small platforms by size, and the drafted Guidelines for Implementing Subject Responsibilities on Internet Platforms (互联网平台落实主体责任指南) (“Responsibilities Guidelines”) impose extra responsibilities and obligations when a platform falls into the category of “super” or “large”, with the purpose of securing fair competition, equal internal governance, and an open ecosystem. China is certainly not alone in doing so. The EU adopted the Digital Markets Act (“DMA”) on July 18 2022,. At the other side of the Atlantic, the U.S. House of Representatives, based on a similar idea, formed a set of five bills, trying to implement regulations on Big Tech companies to hold them accountable for a number of anti-competitive conduct. All these guidelines and proposed acts have one common goal that is to seek government regulation against big platform operators outside the box of competition law. What are the difference between these rules or proposals, and what should be the future for platform regulation?