About the Legality of "Circumvention"#
Although I am not a legal expert, I will briefly explain.
According to the "Administrative Measures for the Protection of International Networking Security of Computer Information Networks" in the National Legal Database National Legal Database (flk.npc.gov.cn)
Article 5 states that no unit or individual shall produce, copy, access, or disseminate the following information through international networking:
(1) Inciting resistance and undermining the implementation of the Constitution, laws, and administrative regulations;
(2) Inciting subversion of the state power and overthrowing the socialist system;
(3) Inciting secession of the country and undermining national unity;
(4) Inciting ethnic hatred and discrimination, and undermining ethnic unity;
(5) Fabricating or distorting facts, spreading rumors, and disrupting social order;
(6) Promoting feudal superstition, obscenity, pornography, gambling, violence, murder, and terrorism, and inciting crimes;
(7) Openly insulting others or fabricating facts to defame others;
(8) Damaging the reputation of state organs;
(9) Other acts that violate the Constitution, laws, and administrative regulations.
Therefore, regardless of whether "circumvention" is illegal, engaging in the above-mentioned activities is illegal!!!#
Next, let's discuss whether "circumvention" is illegal:#
In most reports on the illegality and punishment of circumvention, without exception, reference is made to the Interim Provisions of the People's Republic of China on the Administration of International Networking of Computer Information Networks revised on May 20, 1997:
Article 6 states that computer information networks must directly connect to the international network using the international entry and exit channels provided by the Ministry of Posts and Telecommunications' national public telecommunications network. No unit or individual may establish or use other channels for international networking.
However, many places say that this administrative regulation has a supplementary clause, which refers to the physical channels used for international networking mentioned above. I have been unable to find the source of this statement.
But I still found a breakthrough.
In the Wikisource, there is a passage that says this is stipulated in the "Implementation Measures for the Interim Provisions of the People's Republic of China on the Administration of International Networking of Computer Information Networks" issued by the State Council. Note that this passage adds the four words "implementation measures" that were not mentioned in the previous "Interim Provisions of the People's Republic of China on the Administration of International Networking of Computer Information Networks".
Do not underestimate these four words, as the content stipulated in them is quite different. This "Implementation Measures" specifies that the international entry and exit channels refer to the physical channels used for international networking.
But then the problem arises again. Wikisource is not a professional legal document, and I also put a lot of effort into finding out whether the State Council really has this regulation.
But hard work pays off, and I found this regulation in Issue No. 7 (Total No. 899) of the 1998 Gazette of the State Council of the People's Republic of China
Article 3 The following terms used in these measures shall have the following meanings:
(3) International entry and exit channels refer to the physical channels used for international networking.
Therefore, based on this legal provision and the characteristics of VPN, which establishes a virtual private network on the existing international entry and exit channels regulated by the Ministry of Posts and Telecommunications to achieve encrypted communication of information data, I believe that circumvention is not currently an illegal act.