Author: Shao Jiadian, Liu Honglin

If you were lamenting last year that RWA was just a high-end game played by overseas financial institutions, this year you have likely heard the term "RWA" in art exchanges, farms, and even liquor factories.

RWA projects in mainland China have long ceased to chase traditional U.S. Treasury bonds or commercial real estate, instead taking a different path, adopting a "local lifestyle" approach. Think about it: Malu grapes, airport VIP lounges, liquor pickup rights… It sounds no longer cold, but rather infused with a bit of the romanticism of exploration and grounded practicality.

Next, let’s discuss how this group of "light and beautiful" mainland RWA projects is dancing a new dance between blockchain and the real economy, and what invisible risks they may harbor.

The Current State and Innovative Practices of RWA in Mainland China

1. Asset Types: "Lightweight" Attempts at Consumer Rights and Industry Integration

In mainland China, RWA is no longer confined to traditional financial assets with high-frequency trading but is targeting consumer scenarios that are closer to everyday life. You might see airport VIP lounge services turned into tokens, where users no longer hold abstract digital currencies but actual rights that can be exchanged for a cup of coffee or a waiting seat. For example, the Malu grape RWA project is quite interesting—it turns grape pickup rights into tokens, where investors are not buying bonds or equity but rather the expectation of whether "this year's farmers can grow good grapes." This model tightly integrates traditional agriculture with blockchain technology but also exposes a problem: if the weather is bad and yields decline, how is the value behind the tokens calculated? This gives a sense of "inevitable ambiguity behind innovation."

2. Technical Path: Alliance Chain Exploration in a Semi-Closed Ecosystem

Most RWA projects in mainland China choose to use private or alliance chains, and trading platforms are often limited to art exchanges or digital exchanges. The advantage of this approach is that data is kept in-house, making it easier for regulatory authorities to intervene; however, it loses the freedom of interconnectivity and liquidity found in global public chains. Take "Wine Domain Spirit" as an example; it issued "wine certificates" based on an alliance chain of boundary intelligence, with trading strictly limited to specific platforms. This is akin to a refined little tavern that, while having good flavors, struggles to compete with the international brands of star-rated hotels.

3. Compliance Framework: The "Gray Area" of Regulation and Technical Arbitrage

Currently, there are no specific laws or regulatory policies for RWA in mainland China, and many projects can only wave the banner of "rights certificates" in an attempt to avoid being classified as securities. However, everyone knows that "regulators are not fools." Even if you superficially claim "no promised returns," as long as users think "it will rise," you may be edging towards "regulatory gray areas" or even "disguised deposit-taking." Many project parties have confidently stated, "This is not a security; users can only operate within the platform, and there’s no way to trade," but the reality is that users will always secretly seek to hedge risks off-platform, which means that any leads obtained by regulatory authorities will not be easily overlooked.

Comprehensive Analysis of Compliance Risks in Mainland China's Unique RWA

RWA projects in mainland China are like a hot stir-fry; they taste good, but if the heat is not controlled well, problems can easily arise.

1. Asset Confirmation—Concerns in the "Gray Area"

Take art RWA as an example; some project parties may use "digital authentication certificates" to boast about their ownership proof, but the problem arises: if the data behind the certificate is falsified or the authentication is erroneous, the blockchain cannot roll back. It’s like buying a bottle of "genuine imitation" cola at the supermarket; no matter how beautifully the label is written, it cannot cover up the poor actual taste.

2. Securities Attributes—Is Playing "Close to the Edge" Really Safe?

Many projects operate with the approach: "This is just a rights certificate, definitely not a security!" But as long as you give users the expectation of "it will rise," even if you clearly state that trading is not allowed, users will still entertain themselves off-platform. How do regulators view this? They directly use "disguised deposit-taking" to frame it. As I often say, superficial avoidance does not mean there are no risks; regulators have sharp eyes!

3. Cross-Border Data and Privacy Protection—The Real Dilemma of "Double Pressure"

Some RWA projects involve overseas investors, and the cross-border transmission of personal information and transaction records must strictly comply with the Personal Information Protection Law. However, in reality, many projects lack compliant data channels, and several alliance chains have leaked user data due to improper node permissions. Imagine that while you think your data is safely stored, hidden behind it is the risk of privacy leakage; this is indeed a double blow.

Comparison with Mature Overseas Projects: Innovation and Gaps Coexist

1. Asset Selection Logic: Coexistence of Financialization Depth and Innovation

Overseas RWA projects mainly focus on "hard assets," such as government bonds, real estate, and supply chain receivables, with clear value anchoring and stable cash flow. For example, Ondo Finance in the U.S. achieves stable returns through the tokenization of government bonds, while Hong Kong's charging pile RWA enhances transparency based on real equipment data. In contrast, mainland projects tend to lean towards consumer rights and agricultural products as "soft assets," lacking depth in financialization, but their social value in small-scale financing and inclusive finance (such as supporting farmer financing) is commendable.

2. Technical Standardization and Data Credibility

The Hong Kong Monetary Authority promotes the compliant development of digital assets through the Ensemble project sandbox, emphasizing data credibility and transparency, with underlying data often being real-time uploaded via IoT devices. In contrast, much of the data in mainland China still relies on manual entry, inevitably raising concerns about the risk of data tampering.

3. Market Maturity and Regulatory Collaboration

Hong Kong has formed a compliance framework that integrates "regulatory sandbox-industry standards-judicial collaboration." For instance, the charging pile RWA project, a collaboration between Ant Group and Longxin Technology, achieves compliant connections between mainland assets and overseas funds through a Hong Kong SPV structure. However, mainland projects are limited by foreign exchange controls and poor regulatory communication, and market maturity still needs improvement.

Optimization Path: How to Forge a "Compliance and Self-Discipline" Path for RWA?

To truly carve out a sustainable development path for RWA projects in mainland China, it is essential to connect the joints in regulation, technology, and market ecology.

1. Establish a "Categorized Regulation" Framework

For RWA projects that merely provide exchange services, similar to membership systems, such as airport VIP lounges or grape pickup rights, they can completely follow the "consumer goods regulation" route—clearly defining the scope of services and responsibilities. Conversely, for RWA with clear income rights, they should refer to securities standards and adopt a "securitization sandbox" to ensure full compliance with information disclosure, KYC, and AML. This way, you won’t fear regulation, and regulators won’t arbitrarily find fault.

2. Promote the Combination of Technical Standards and Judicial Evidence Preservation

Mandate that projects involving physical assets on-chain adopt a dual-channel verification of "IoT + blockchain," ensuring that data is first preserved by judicial authentication institutions before being uploaded to the blockchain, guaranteeing that every piece of data is traceable. At the same time, support local courts in exploring "on-chain evidence" acceptance rules to lower the threshold for user rights protection.

3. Explore Compliance Paths for "Domestic Assets-Offshore Financing"

Learn from the model of Longxin Technology in Hong Kong, issuing RWA tokens through a Hong Kong SPV, utilizing the regulatory sandbox to introduce foreign capital, and collaborating with the foreign exchange administration to pilot an "RWA cross-border financing whitelist," simplifying the approval process for fund repatriation. This can both broaden financing channels and ensure compliance, avoiding the pitfalls of P2P.

Summary by Lawyer Mankun

There is currently no unified answer on how to navigate the path of RWA in mainland China. From the projects observed so far, "not financial, not securities, only services" is not a panacea. If you merely "play dumb" for the sake of compliance, you will ultimately struggle to escape the heavy hand of regulation; projects that genuinely want to succeed must ultimately clarify one point: are you self-disciplined for long-term development, or are you gambling for short-term financing? Today it may be grapes and liquor, but if tomorrow it turns into "RWA version of P2P," the entire industry will have to start over.

In summary, RWA projects in mainland China have unique advantages and practical value in their exploration of "light assetization" and "localization," but there are still many shortcomings in asset confirmation, technical standards, and regulatory collaboration. Only through "technical standardization + regulatory sandbox + cross-border collaboration" can we achieve a triple breakthrough to stand out in fierce market competition and truly realize the ideal of empowering the real economy with blockchain.

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