If you were lamenting last year that RWA was just a high-end game played by overseas financial institutions, this year you might have already heard the term 'RWA' at cultural exchange centers, farms, or even distilleries.

RWA projects in mainland China have long ceased to pursue traditional U.S. government bonds or commercial real estate, instead forging a new path focused on 'local life.' Consider Malu grapes, airport lounges, and liquor picking rights... They sound no longer cold but rather infused with a bit of the romantic explorer spirit and practical down-to-earth value.

Next, let's discuss how these 'light and beautiful' mainland RWA projects are performing a new dance between blockchain and the real economy, and what invisible risks they hide.

The current state and innovative practices of RWA in mainland China

1. Asset type: A 'lightweight' attempt to integrate consumer rights and industries

In mainland China, RWA is no longer confined to traditional financial assets with high-frequency trading, but aims at consumption scenarios that are closer to life. You might see airport lounge services being 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 boarding spot. For example, the Malu grape RWA project is quite interesting—it turns grape picking rights into tokens, where investors are not buying bonds or equity, but rather the expectation of whether 'farmers can grow good grapes this year.' This model closely integrates traditional agriculture with blockchain technology but also exposes a problem: if the weather is poor and yields decrease that year, how is the value behind the tokens calculated? This gives a sense of 'inevitable ambiguity behind innovation.'

2. Technical path: Exploration of consortium chains in a semi-closed ecosystem

Most RWA projects in mainland China choose to use private or consortium chains, and trading platforms are often limited to cultural exchange markets or digital asset exchanges. The benefit of this approach is that data is controlled in-house, making it easier for regulators to intervene; however, on the other hand, it loses the freedom of interconnection and circulation found in global public chains. Take 'Wine Domain Spirit' as an example; it issues 'wine certificates' based on a boundary-smart consortium chain, with transactions strictly limited to specific platforms. It's like a fine little tavern; while the taste is good, it struggles to compete with the international brands of star-rated hotels.

3. Compliance framework: The 'gray area' of regulation and technological arbitrage

Currently, there are no specific regulations or regulatory policies for RWA in mainland China, and many projects can only wave the banner of 'rights certificates' in an attempt to evade being classified as securities. However, everyone knows that 'regulators are not fools'; even if you superficially claim 'no commitment to returns,' as long as users think 'it will rise,' you may end up on the edge of 'playing on the fringes' or even 'disguised deposit-taking.' Many project parties have confidently said, 'This is not a security; users can only operate within the platform without the ability to trade,' but the reality is that users always find ways to secretly hedge risks off-platform, which means that the clues regulators obtain will not be easily overlooked.

A comprehensive analysis of the compliance risks of RWA features in mainland China

Mainland RWA projects are like a stir-fried dish; they taste good but can easily go wrong if not properly controlled.

1. Asset confirmation—The hidden worries of the 'gray area'

Taking art RWA as an example, some project parties use 'digital authentication certificates' to boast about their ownership proof, but the problem arises: if the data behind the certificate is fabricated or misidentified, the blockchain cannot roll back. It's like buying a bottle of 'true imitation' cola at the supermarket; no matter how beautiful the label is, it cannot hide the poor actual taste.

2. Securities attributes—Can playing 'on the fringes' be safe?

Many project operating methods are: 'We are just rights certificates, definitely not securities!' 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 find ways to entertain themselves off-platform. How does the regulatory department view this? They directly label it as 'disguised deposit-taking.' As I often say, superficial evasion does not mean there are no risks; regulators are keenly observant!

3. Cross-border data and privacy protection—The real dilemma of 'dual 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 numerous consortium chains have experienced user data leaks due to improper node permissions. Imagine, while you think the data is securely stored, hidden risks of privacy breaches lurk behind, which truly feels like a double blow.

Comparing with mature overseas projects: Innovation and gaps coexist

1. Asset selection logic: Coexistence of financialization depth and innovation

Overseas RWA projects are mostly based on 'hard assets,' such as government bonds, real estate, and supply chain receivables, with clear value anchors and stable cash flows. For example, the U.S. Ondo Finance achieves stable returns through the tokenization of government bonds; the RWA of charging piles in Hong Kong enhances transparency based on the data from physical equipment. In contrast, mainland projects tend to lean towards 'soft assets' like consumption rights and agricultural products, lacking in financialization depth; however, their social value in micro-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 to the blockchain through IoT devices. Meanwhile, many data inputs in mainland China still rely primarily on manual entries, inevitably raising concerns about the risk of data tampering.

3. Market maturity and regulatory collaboration

Hong Kong has formed a tripartite compliance framework of 'regulatory sandbox - industry standards - judicial collaboration.' For example, the charging pile RWA project that Ant Group cooperated with Longxin Technology achieved compliant connection between mainland assets and offshore funds through the 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 enable mainland RWA projects to truly carve out a path for sustainable development, it is essential to break through the barriers in regulation, technology, and market ecology.

1. Establish a 'classified regulation' framework

For RWA projects that simply exchange services, similar to membership systems, such as airport lounges or grape picking rights, it is entirely feasible to follow the 'consumer goods regulation' approach—clearly defining the scope of services and responsibilities. Conversely, for RWAs with obvious income rights, one must 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 integration of technical standards and judicial evidence preservation

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

3. Exploring compliant paths for 'domestic assets - offshore financing'

Drawing on the model of Hong Kong's Longxin Technology, issue RWA tokens through a Hong Kong SPV, utilizing a regulatory sandbox to attract foreign investment and pilot the 'RWA cross-border financing whitelist' in collaboration with the foreign exchange administration, simplifying the fund repatriation approval process. This not only broadens financing channels but also ensures compliance, avoiding the pitfalls of P2P.

Summary by Lawyer Mankun

How mainland RWA should proceed currently lacks a unified answer. From the projects observed, 'non-financial, non-securities, just services' is not a panacea. If you are merely 'playing dumb' for compliance, you will ultimately not escape the heavy hand of regulation; truly ambitious projects must clarify one point: are you practicing self-discipline for long-term development or gaming for short-term financing? Today it might be grapes and liquor, but if tomorrow it turns into 'RWA-style P2P,' the entire industry will have to start over.

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


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Authors: Shao Jiadian, Liu Honglin