BG5JFI No, I received a reply from MIIT today.

It seems that the Ministry of Industry and Information Technology is taking a broader approach, not limiting communication to simply transmitting and receiving radio signals, but rather focusing on the actual recipient of the information... Furthermore, it appears they are prioritizing urgent matters over routine communications, meaning that even in emergency situations, only third-party messages related to the emergency can be transmitted.
(When I initially wrote the consultation letter, I provided a detailed explanation of what constitutes a third-party message and referenced FCC regulations. Therefore, it's unlikely that there was any misunderstanding on the part of MIIT.)