Joint Data Responsibility in Global Digital Trade: A Meso-Level Comparative Analysis of the European Union, the United States, and China

Digital trade exposes increasing tensions between cross-border data flows, personal data protection, and national security. Existing scholarship has largely addressed these issues either at the macro level, through debates on data sovereignty, or at the micro level, through the obligations of individual data controllers. This article bridges an overlooked gap by conceptualizing joint data responsibility as a meso-level governance mechanism shaping accountability in multi-actor data processing. Using a functional comparative approach, the study examines the European Union (EU), the United States, and China through a three-dimensional framework of identification criteria, liability allocation, and transparency obligations. The analysis reveals persistent regulatory divergence rather than convergence: the EU adopts a rights-based model centered on joint controllers and strong external remedies; the US relies on decentralized, contract-driven arrangements and ex post enforcement; and China has developed a state-led hybrid model characterized by risk-based differentiation, platform responsibility, and administrative oversight. The findings suggest that fragmentation in global digital trade governance reflects deeper institutional logics, underscoring the limits of substantive harmonization and the growing importance of procedural interoperability.