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Hiring a China Lawyer From the US, Europe, Australia/NZ or the Gulf: What to Send First

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You do not need to come to China. Most work starts with an email. This page explains what I need first. It shows which documents need formal certification, and when. It also covers what differs depending on where you are.

Responsible lawyer: Adrian Liu · PRC lawyer, Xiamen · 74 supplier-dispute lawsuits · English & Chinese

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Flags show where clients are based. I practise Chinese law only, from Xiamen.

What to send first

A few documents tell me most of what I need:

Add your deadline if there is one.

I ask for the parties’ names first. I have to check for conflicts before I read anything else. Please hold back drawings, source files and anything else confidential. Wait until we have agreed how to transfer them.

What happens next

  1. Conflict check. Done on the names alone.
  2. Written scope and fee. Most work is for a fixed fee in US dollars. The fee is set out before any paid work starts. See fees and process.
  3. Engagement terms. I go through them with you when we talk.
  4. Payment. The terms are in your written proposal, and payment details come with the confirmed invoice. They are never changed by message. We do not receive, hold or pass on money for clients or third parties.

I reply to a first enquiry within one calendar day.

When formal documents are needed

Only when a Chinese court is involved. A foreign company that sues in China has to prove three things. Each proof has its own formalities.

An apostille is a single certificate from the country where the document was made. It confirms the document is genuine. Legalisation means the Chinese embassy or consulate certifies the document. Which step applies also depends on the law of the country where the document was made and on its treaties with China. A lawyer should confirm it for your documents.

What the court needsDocumentFormality if it comes from abroad
That the company existsCertificate of incorporation or register extractNotarised, then apostille or legalisation
That the signatory can represent itCertificate of incumbency or board resolutionNotarised, then apostille or legalisation
That the lawyer is authorisedPower of attorney, with special authorisation to settle and appealNotarised, then apostille or legalisation; none if signed before a Chinese judge, in person or by video

Signing before a judge by video is available for civil and commercial claims at first instance, meaning in the first court to hear the case. It removes the foreign formalities for the power of attorney only. The company documents still need them. The full rules, with the articles and cases, are in how to instruct a Chinese lawyer from abroad.

Start on these documents as soon as a claim looks likely. They usually take the longest on your side. Nothing can be filed until they arrive.

Want to check one document by country? Try the free apostille check for Chinese court cases. Your answers stay in your browser.

What differs by region

Which step applies also depends on the law of the country where the document was made and on its treaties with China. A lawyer should confirm it for your documents.

United States

The United States is a party to the Apostille Convention, so an apostille replaces legalisation at the Chinese embassy. Chinese courts have accepted apostilled US documents. See how to instruct a Chinese lawyer from abroad.

One point for your contracts. China and the United States have no treaty on recognising each other’s court judgments. Without one, a Chinese court recognises a US judgment only on the basis of reciprocity. It assesses this case by case. Reciprocity asks whether the country that gave the judgment would recognise a Chinese one. If the supplier’s assets are in China, a clause that sends disputes to a US court is hard to use against them.

Canada

Canada has been a party to the Apostille Convention since 11 January 2024. This means an apostille replaces legalisation at the Chinese embassy. Documents in French need a Chinese translation before filing, just as English ones do.

Canada, like the United States, is a party to the CISG, the UN sales convention. It applies to your contract with a Chinese supplier unless the contract excludes it. Xiamen is 12 to 13 hours ahead of Toronto and 15 to 16 hours ahead of Vancouver. Calls usually fall in your early morning or evening.

Europe

The United Kingdom is a party to the Apostille Convention. So are the EU member states I am most often asked about, including Germany, France, Italy, Spain, the Netherlands and Poland. For them, the apostille route applies. Documents in any language other than Chinese need a Chinese translation from a qualified translation company before filing.

Your country may be a party to the UN sales convention (CISG). If so, the Convention applies to your contract with a Chinese supplier unless the contract excludes it. This holds even where the contract chooses Chinese law.

Australia and New Zealand

Both are parties to the Apostille Convention. Xiamen is two to three hours behind Sydney and four to five behind Auckland. Calls fit inside your working day.

The Gulf

Saudi Arabia, Bahrain and Oman are parties to the Apostille Convention. For Saudi Arabia, it has been in force since 7 December 2022. Oman applies it to civil documents only. Its commercial and customs documents still need legalisation. The UAE, Qatar and Kuwait were not parties when this page was last checked. So documents from those three are legalised by the Chinese embassy or consulate. Documents in Arabic need Chinese translations for filing.

China has judicial assistance treaties with the UAE and Kuwait. These are treaties on cooperation between courts, and they cover court judgments. China’s agreement with Saudi Arabia is also in force. For what this means when you collect from a Chinese supplier, read enforcing a Gulf judgment or award. Also see the page for buyers in the Gulf.

Membership of the Convention changes. A state can also object when another state joins. I check the position for your country before you start on the documents.

If your company is registered in Hong Kong

Hong Kong follows a different route. A notary recognised by the mainland notarises the documents. China Legal Services (Hong Kong) Limited then stamps them and sends them on. For a Hong Kong document used in a mainland court, an apostille alone is not the route.

Questions clients ask first

Do I have to travel to China?

For business matters, no. Contract work, supplier checks and letters are done remotely. In court, your PRC lawyer appears for you. You can sign the power of attorney before the judge by video. Divorce cases are different, because the court usually expects you to attend. See family and inheritance matters. If you are inheriting in China, see how June Zhang helps heirs living abroad.

Can my own lawyer stay involved?

Yes. Only a PRC lawyer can appear as a lawyer in a Chinese court. Your lawyer at home can still advise you and work with me on the file. See PRC legal support for overseas counsel.

What language do we work in?

English with you. Chinese with the supplier and the court. Contracts meant to be enforced in China are normally bilingual. I normally draft them so that the Chinese version controls if the two differ.

Can you talk to the supplier for me?

Yes. Where negotiation is the next step, I can take part in it directly, in Chinese. This is a defined scope, agreed in writing.

Send the short version

Tell me where your company is registered, which Chinese company you are dealing with and what has happened. I will tell you where you stand, which route fits and what each document needs. Describe your situation →

General information on instructing a PRC lawyer. It is not advice on a particular matter. Apostille Convention status checked against the HCCH status table on 30 September 2026. The legal sources for the court formalities are listed in the linked guide.