> "China" (as in the CCP) does not, in fact, have the data. They're leveraging a network of mostly-private companies to do the dirty work for them

The difference is that the CCP has every right to shut down businesses and they make the Law directly. No provisions can be made by external parties, there is no separation of power. So in practice all companies work in accordance with the CCP and will bend to their requests. In the US there are still companies which can and do refuse the federal government's requests to provide data without sufficient reason.