Recognition of foreign judgments in China

A foreign court judgment can be recognized and enforced in China where an international treaty applies, or on the basis of the principle of reciprocity (互惠). Chinese courts have taken an increasingly open, pro-recognition stance in recent years, and several recent cases adopted a pragmatic, fact-based reciprocity approach.

• Conflict-of-law and treaty-coverage assessment
• Reciprocity-route analysis and evidentiary package
• Application to the competent intermediate court
• Post-recognition enforcement

For cross-border commercial disputes, the New York Convention arbitral-award route is usually faster and more predictable than the judgment-recognition route; we advise on the optimal path at intake.