Comparative Analysis of Child Pornography Laws between China and the US: Suggestions for the Revision of Chinese Criminal Law Based on a Systematic Literature Review

Child pornography poses significant risks to children's well-being and safety, with the proliferation of digital platforms exacerbating its accessibility and prevalence. This paper conducts a comparative analysis of child pornography laws in the United States and China, highlighting key differences in definitions, enforcement measures, and protection of children's rights. While the US legal system has made strides in addressing child pornography through stringent penalties and protective measures, China's legal framework exhibits deficiencies, relying on outdated regulations and lacking specific provisions for combating this crime effectively. Recommendations for revising Chinese criminal law include clarifying the concept of child pornography, strengthening legal protections for children's rights, expanding regulations to cover possession and virtual child pornography, and enhancing victim protection measures in criminal proceedings. Aligning with international standards and enhancing enforcement mechanisms can improve China's ability to combat child pornography, safeguard children's rights, and create a safer online environment. Adapting legal frameworks to address evolving digital threats is crucial in ensuring the protection and well-being of vulnerable individuals, particularly children, in today's digital age.