China Justice Observer

中司观察

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Recognition and Enforcement of Foreign Judgments in China

Can I sue Chinese companies in a district court in California, the U.S., or in Paris, France, and then enforce a judgment in China from those courts?

Most likely, you don’t want to have to go so far away as to sue a Chinese company. You may just want to take your case in the court on your doorstep because you are more familiar with your home state.

However, you are also aware that the vast majority or all of the assets of the Chinese company are located in China. As a result, even if you have won the lawsuit at home, you still need to have your judgment enforced in China.

This concerns the recognition and enforcement of foreign judgments in China.

China has adopted a more friendly attitude towards the enforcement of foreign judgments in China since 2015, with a handful of successful cases concerning recognition of judgments of several countries, including the United States, Singapore and South Korea.

On this basis, China’s Supreme People’s Court(SPC) has started applying new rules in 2022 that will make foreign judgments as likely to be recognized and enforced in China as they are in common-law countries or civil-law countries like Germany.

To date, foreign judgments rendered from the following jurisdictions can or are very likely to be recognized and enforced in China.

i. France, Italy, Spain, Russia, Vietnam, the UAE, Poland, Mongolia, Romania, Belarus, Ukraine, Cuba, Egypt, Bulgaria, Turkey, Kazakhstan, Cyprus, Greece, Hungary, Kyrgyzstan, Uzbekistan, Tajikistan, Morocco, Tunisia, Laos, Lithuania, North Korea, Kuwait, Brazil, Argentina, Peru, Algeria, Bosnia, and Herzegovina: these countries have concluded bilateral treaties with China.  

ii. The US, the UK, Germany, Singapore, South Korea and Thailand: judgments rendered in these countries have already been recognized in China based on reciprocity. 

iii. Australia, Canada, the Netherlands, the British Virgin Islands, and New Zealand: these countries and regions have recognized Chinese judgments and are waiting for China to confirm the reciprocity in future cases.

Contributors of China Justice Observer (CJO)（Guodong Du, Meng Yu, Yahan Wang, Béligh Elbalti, etc.）maintain their focus on this field, and endeavor to share updates on the latest developments with the international community. In addition, Guodong Du and Meng Yu lead a team of attorneys from multiple Chinese law firms, providing legal services in recognition and enforcement of foreign judgments.

For Foreign Judgments Collection Service and more resources, please click here.

For 2022 Guide to Enforce Foreign Judgments in China, please click here. For more countries' guides, please click here.

For the time and expenses in recognition and enforcement of foreign judgments in China, please click here.

For the List of China’s cases on recognition of foreign judgments, please click here.

For the List of China's Bilateral Treaties on Judicial Assistance in Civil and Commercial Matters (Enforcement of Foreign Judgments Included), please click here.

Foreign Judgments in Mozambique through the Lens of the Enforcement of a Chinese Judgment: Liberal Practice in the Shadow of Statutory Rigidity

Wed, 04 Mar 2026 Insights Béligh Elbalti

In April 2025, the Mozambican Supreme Court ruled to recognize and enforce a Chinese monetary judgment of the Primary People’s Court of Nanhai District, Foshan, Guangdong Province (Han Boajun v. Minguei He (Case No. 75/2024-C)). This marks the first reported case where a PRC judgment was enforced in Mozambique.

Chinese Judgments Go Global: Emerging Systemic Challenges and Confidence Deficit

Wed, 04 Feb 2026 China Legal Trends Meng Yu 余萌 , Wenliang Zhang

This post analyzes the historic rise in cross-border judgment enforcement involving China, specifically focusing on the persistent challenges hindering the recognition of Chinese judgments abroad. It identifies two primary obstacles—emerging legal hurdles regarding systemic due process and a "confidence deficit" among Chinese creditors—and argues that addressing these is essential to sustaining the framework of mutual recognition.

Positive Cycle: Chinese Court Enforces Korean Trademark Judgments, Confirming De Jure Reciprocity with South Korea

Mon, 22 Sep 2025 Insights Meng Yu 余萌

In December 2024, the Beijing Fourth Intermediate People’s Court ruled to recognize and enforce two South Korean trademark judgments (SD Biotechnologies Co. Ltd v. LAP F&C (2022) Jing 04 Xie Wai Ren No.23-1). This marks the second reported case of a Korean IP-related judgment being recognized in China, following a similar case four years prior.

Beyond the Memorandum: Shanghai Court Enforces Singapore Judgment by Confirming “Reciprocal Consensus” Under China’s New Framework

Tue, 19 Aug 2025 Insights Meng Yu 余萌

On January 8, 2025, the Shanghai International Commercial Court recognized and enforced a Singapore High Court monetary judgment in Zhao v Ye (2023) Hu 01 Xie Wai Ren No. 28. It marks the first judicial confirmation of “reciprocal consensus” between China and Singapore under the 2022 reciprocity criteria, based on the China-Singapore Memorandum of Guidance (MOG).