Mark Scott is a contributing editor at Tech Policy Press.
When the European Commission announced its €120 million fine against Elon Musk’s X for breaches of the bloc’s online safety rules, the decision reignited a transatlantic spat between Washington and Brussels.
US Vice President JD Vance scolded the European Union for “attacking American companies over garbage.” Henna Virkkunen, the Commission’s executive vice president, said the bloc was “holding X responsible for undermining users’ rights.”
Yet on the same day that Brussels issued its first-ever penalty under its Digital Services Act against X, EU officials also reached a settlement with TikTok, the China-linked social media giant, related to similar breaches to the rules’ transparency obligations.
The parallel decisions — one including a fine against an American firm and political backlash from the White House, another targeting a tech giant with links to China, which involved commitments to uphold Europe’s online safety rules — is starting to become a trend.
Where US tech giants are vocally pushing back against Europe’s tech regulation, their Chinese counterparts are quietly negotiating deals to comply with the bloc’s rules — and avoid hefty fines.
It represents a significant departure in how the US and China — undeniably the most important geopolitical and technological powers in the world — approach their relations with the EU, whose own international ambitions include enforcing the most ambitious set of tech rules anywhere in the democratic world.
Those aspirations may be wavering, given the internal revamp that has seen Brussels embrace an increasingly deregulatory agenda.
But the contrasting willingness of both US and Chinese companies to comply with Europe’s DSA mirrors wider shifts in the geopolitics of global tech governance.
Under President Donald Trump’s second term in the White House, Washington has pulled back from international partnerships on digital rulemaking and publicly stated its ambitions to dominate emerging technologies like artificial intelligence. It has tied commercial agreements and trade deals with countries’ willingness to embrace the US’ laissez-faire approach to tech regulation.
Seeing an opportunity, Beijing has positioned itself as a stable diplomatic partner on tech.
It has worked with developing economies to lobby for digital commitments within the United Nations. It has flooded international tech standards bodies to promote its authoritarian view of the internet. It has outfoxed Washington to secure a UN cybercrime treaty that significantly undermines human rights.
US and Chinese tech companies have made their own decisions — outside of government relations — over whether to comply with Europe’s DSA. But the parallels between their corporate actions and the steps taken by their respective governments is uncanny.
Earlier this year, for instance, the European Commission agreed binding commitments from AliExpress after EU enforcers discovered a series of violations, including the sale of illegal goods, via the Chinese e-commerce giant. In 2024, TikTok also withdrew one of its products, which targeted children, from the 27-country bloc in response to complaints from European officials.
Separate ongoing DSA investigations also focus on Temu and Shein, the Chinese e-commerce firms — dispelling US criticism that Europe’s online safety rules are unfairly targeted at American companies.
In contrast, YouTube, whose services are under scrutiny for failing to protect children online, told US lawmakers that the EU’s online safety rules could force the tech giant “to remove lawful content, jeopardizing the companies’ ability to develop and enforce global policies that support rights to free expression.”
Alphabet, YouTube’s parent company, denies any wrongdoing under the DSA.
Meta, which has already been fined €200 million under Europe’s separate digital antitrust regulation, is currently under multiple investigations linked to the bloc’s DSA — accusations the tech giant denies. The social media giant has pulled back extensively on its content moderation commitments, including the termination of its global fact-checking program.
Joel Kaplan, the company’s chief global affairs officer, told a Brussels audience in early 2025 that fines under Europe’s tech regulation were akin to unfair tariffs — language that mirrors similar complaints from the Trump administration. Meta remains equally concerned about the bloc’s revamped online safety and digital antitrust rules.
“European regulators have sort of measured success based on the number and size of fines that they’ve been able to assess against US tech companies,” he said.
It’s still unclear whose strategy will prove successful.
X is likely to appeal its €120 million fine in a legal process that will drag on for years and could result in European judges overturning Brussels’ ruling. On Dec 7, Nikita Bier, the company’s head of product, said the tech giant had stopped the European Commission’s X account from buying ads, allegedly for breaching X’s terms of service.
Chinese social media and e-commerce giants may still face blockbuster fines under the DSA, despite their willingness to engage with EU officials. Many EU regulators and officials say they prefer negotiated settlements, which force companies to comply with the regulation, than hefty fines and drawn-out legal appeals.
Yet in taking such contrasting approaches to Europe’s online safety rules, American and Chinese tech giants are shadowing equally opposing tactics from their governments’ officials when it comes to global tech rules.
As Brussels’ enforcement of the bloc’s digital rulebook gains momentum, that disconnect will only become more acute — and will increase the divide between China and the US on tech.
