Regarding the application and delegation of Han Script Single Character IDN Generic Top-Level Domains for the next round of New gTLD expected to run in 2026, we would like to express the following views:

1.    In the SAC052 clearly states that “the SSAC recommends a very conservative approach to the delegation of single-character top-level domains. In particular, ICANN should disallow by default the delegation of all single-character IDN TLDs in all scripts; exceptions are possible, but only after careful consideration of each individual case.” On the contrast, ICANN is taking considerations for the Application of Han script single character IDN in the next round opening. Currently, in terms of security and stability, we believe that ICANN is considering opening Han scrip single character IDN, but has not solved all the problems that need to be solved. It is definitely not a conservative approach that ICANN has taken.

In addition, concerns can also be raised from the perspective of domain name security issues such as whether the delegation of Han script single characters IDN gTLDs will increase the risk of domain abuse. We have also noticed that there are still questions from some SO and AC regarding opening the application of Han script single character IDN TLDs. The members of CJK GPs do not all support of opening Han scrip single character IDN.

Due to the above issues, we would like to request a re-evaluation of the security of openness, especially considering that only the Han script single character IDN TLDs are currently included in delegation. However, considering the differences in usage, user habits, and diverse meanings of the Han script single character, it is necessary to conduct a separate evaluation on this issue, and to communicate and consult with the competent authorities of the countries and territories where the Han scrip single character IDN TLDs are mainly used on security. Moreover, we would like to suggest that the ICANN Board shall communicate with ccNSO, ALAC, GAC and other organizations, especially representatives from countries and territories where the Han script single characters are mainly used. ICANN shall fully listen to the opinions of relevant communities and reach consensus on the relevant issues.

2.    The JIG also suggested moving forward with the implementation of single character IDN TLDs while addressing relevant technical, linguistic, and policy matters.

From the current perspective, the technology, language, and policy issues are not solved. If it is opened rashly, according to the situation of the first round of opening, single character IDN TLD are bound to cause more new problems, such as trademarks and intellectual property, public interests, user rights, and other aspects.

In addition, we would like to remind that ICANN is bound by its Articles of Incorporation and Bylaws to respect relevant principles of international law and applicable local law. There are Chinese laws and regulations related to language, trademark and intellectual property rights, geographic name management, organization name management and other laws and regulations also involved with language and other related issues. Therefore, according to the relevant laws and regulations of China, we urge ICANN to conduct a legal compliance assessment and comply with relevant regulatory requirements before opening the application of Han single character IDN.

3.    In the CGP Statement on the Single Character IDN TLD Implementation, CGP has expressed that they have completed the task of the Root Zone Label Generation Ruleset (RZ-LGR). “CGP did not distinguish between single-character labels and multiple-character Chinese strings.”From the perspective of the CGP and CJK GPs, have repeatedly stated that RZ-LGR is only a technical issue and is not specifically targeted at single or multiple characters, and they have not been involved in registration policy discussions concerns about the application and delegation of Chinese single character TLD in the next round.

Despite knowing the attitude of CGP/CJK GPs, ICANN still insists on linking openness to whether CJK GPs will provide more guidance. According to the next steps of Considerations for the Application of Han Script Single Character IDN Generic Top-Level Domains, “Based on the inputs from the Chinese, Japanese, and Korean Script Generation Panels, no further analysis is required. So, ICANN org is able to move forward with implementing the policy recommendations regarding the single character IDN gTLDs in the Han script. “

From the above statements of CGP/CJK GPs and ICANN, there is obviously a logical contradiction, that is, ICANN added openness to a WG and experts who clearly stated that openness is unrelated to it; At the same time, given the complex situation related to single character openness mentioned earlier, there is a clear lack of a complete evaluation of whether openness meets the conditions and reach to a full complete solution for application of Han script single character IDN TLDs.

Based on three points of views mentioned, ICANN has not completed a full competent assessment and has not addressed all relevant concerns of most related stakeholders/parties. Therefore, we recommend that ICANN not open application of of Han Script Single Character IDN in the next round in 2026.

Regarding the application and delegation of Han script single character IDN gTLDs in the next round in 2026, firstly, we believe that ICANN is not taking a conservative approach that there are still remaining unsolved issues related to security and public policy.

Secondly, CGP and ICANN have obviously contradictory views on the relation between the CGP and the opening the application and delegation of Han script single character IDN gTLDs.

That is, CGP insists that the team ”should NOT and has NOT be involved in registration policy discussions on single character issue”, referring to the feedback and comments from CGP/CJK GPs and their members, while ICANN links openness to whether CJK GPs will provide more guidance.