It is ICP license you talked about, you can find some information here:
https://support.cloudflare.com/hc/en-us/articles/209714777-ICP-FAQ

It is almost impossible to register a .cn or .com.cn domain in China for a 
foreign company which do not have a legal entity in China, legally.
The websites will be blocked for access by the ISP/Telco if the websites were 
hosted in China but do not have valid ICP licenses or even the IPs have not 
been registered to the government. if it is not that hard before, but it has 
more and more regulatory polices.

For Letsencrypt, if you want to own the .cn or .com.cn domain legally, think of 
to set a legal entity in China.

Thanks,
Xiaosheng Tan



在 2016/12/20 上午10:54,“dev-security-policy 代表 Samuel 
Pinder”<dev-security-policy-bounces+tanxiaosheng=360...@lists.mozilla.org 代表 
[email protected]> 写入:

    As far as I know, transferring by entering the name and address of the
    person to transfer to would work via your registrar. But then CNNIC
    will want to see a photo of a passport showing the name of the person
    in full within a certain deadline, otherwise the domain would be
    suspended. A registrar gathers this from the intended registrant and
    they send it to CNNIC on your behalf, you don't send it directly to
    CNNIC. Of course there is distinction between a person and a company,
    if you're transferring to a company, you'll need business documents
    showing registration details.
    See this FAQ: https://cnnic.com.cn/IS/CNym/cnymyhfaq/#8_1
    One more thing to be aware of not listed in the FAQ there: CNNIC will
    want to know if you will be using the domain within China, as that
    requires an ACP licence for any website hosted on port 80, 8080, or
    443. Choosing "no" would mean the domain would resolve, but any
    website on it would be inaccessible within China and would only work
    abroad, since ACP licences *apparently* are only available to Chinese
    companies. What this effectively means for Let's Encrypt, you'd have
    the domain name to protect it, but wouldn't be able to use it within
    China unless you had an actual presence there and acquired an ACP
    licence. I registered a .cn domain some time ago, so just thought I'd
    share my knowledge. Good luck, and sorry it kinda goes outside the
    scope of this thread.
    Sam
    
    
    On Tue, Dec 20, 2016 at 2:28 AM, Richard Wang <[email protected]> wrote:
    > I got the email from Josh, this is my reply:
    >
    > Hi Josh,
    >
    > Glad to receive your formal request email.
    >
    > Yes, it is hard to register a domain for foreigner, I also don't know how 
to transfer to you. What I can do now is to resolute it to your website.
    >
    > As I said we can transfer to you at any time.
    >
    >
    > Best Regards,
    >
    > Richard
    >
    > -----Original Message-----
    > From: dev-security-policy
    > [mailto:[email protected]] 
On
    > Behalf Of [email protected]
    > Sent: Monday, December 19, 2016 12:36 PM
    > To: [email protected]
    > Subject: Re: wosign and letsencrypt.cn / letsencrypt.com.cn
    >
    > We had some trouble figuring out how to purchase a Chinese domain name 
before
    > we launched, so we didn't purchase it then. We've never talked to wosign 
about
    > this before, and we haven't seen the domain used for anything confusing so
    > far. This is our first interaction about it and we're happy to hear that
    > Richard would like to help us out by transferring the domains.
    >
    > Thanks Richard, I'll be in touch.
    >
    > On Sunday, December 18, 2016 at 7:45:16 PM UTC-6, Richard Wang wrote:
    >> I wish everyone can talk about this case friendly and equally.
    >>
    >> It is very common that everyone can register any domain based on the 
first
    >> come and first service rule.
    >>
    >> We know Let's Encrypt is released after the public announcement, but two 
day
    >> later, its .cn domain is still not registered, I think maybe it is 
caused by
    >> the strict registration rule in China, so I registered it for protection
    >> that not registered by Cornbug.
    >>
    >> We don’t use those domains for any WoSign's services that we provide
    >> similar service: https://pki.click/index_En.htm (SSL Wizard, 
StartEncrypt)
    >>
    >> Now, if Mozilla or Let’s Encrypt contact me officially and request to
    >> transfer the two domains to them, no any problem, we can transfer to them
    >> for FREE!
    >>
    >> But please notice that this arrangement is for friendship, not for others
    >> ......
    >>
    >>
    >> Best Regards,
    >>
    >> Richard
    > _______________________________________________
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    > [email protected]
    > https://lists.mozilla.org/listinfo/dev-security-policy
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