The level of regulation isn't close.
I get what you're trying to say, but having just had some meetings on aligning with the latest AI act, as a small startup focusing on adapting open source models for local use, the way it looks now, it seems like we won't have any consumers worth protecting :) (and I'm only half joking. AI act is a joke, and Mistral have been saying this for a while now. We have chinese models launched with permissive licenses, usable everywhere except in the EU. It'd be good comedy if it wouldn't be tragic. ffs! We can't use open source shit!!! It's bananas)
They're monopolies or quasi monopolies.
China has their own because they block Apple Microsoft and Google, they are not competing with them.