The list of offenses from China are foundational to the case for banning Tiktok. They belong to an argument that bootstraps itself. Those points aren't merely offered in a reactionary manner as a way to attempt to refute or deflect other criticisms.

What makes any specific point into whataboutism is its intended use as a counterpoint in a context where it doesn't change the outcome of the argument its responding to.

What does the South China Sea have to do with TikTok?

The "list of offenses" is just meant to say, "China bad, so TikTok bad."