1. The four request types
A foreign party asks for a certified company document. The request is usually one of four.
A chamber of commerce attestation.
A notarized document.
An apostilled document.
A consular legalized document.
Each has a different process, a different timeline and a different cost.
2. The documents requesters most often specify
Not all document types can take all four treatments. The variations matter.
Certificate of origin
Cannot be notarized (it is already an official document), can be apostilled in some localities, can be consular legalized.
Commercial invoice
Notarized, notarized and apostilled, notarized and consular legalized, or CCPIT certified.
Business licence
CCPIT certified, notarized, notarized and apostilled, notarized and consular legalized, or directly apostilled in some localities.
Power of attorney
Notarized with signature appearance, then apostilled or consular legalized.
Free sale certificate
CCPIT certified, notarized, then apostilled or consular legalized.
Contract
CCPIT certified, notarized, then apostilled or consular legalized.
3. The Middle East
The Gulf states are the most demanding group.
Kuwait: consular legalization, with the invoice and certificate of origin commonly legalized together.
Qatar: consular legalization, with the invoice and certificate of origin certified together since 2021.
Iraq: consular legalization through the embassy’s commercial office, with the conformity certificate required for most goods.
Iran: consular legalization with the invoice, certificate of origin and health certificate together.
Jordan: consular legalization, though the WTO free certification list exempts some documents.
Oman: consular legalization for commercial and customs documents, apostille for civil documents.
Bahrain: apostille, being a Convention party.
The UAE: apostille for many documents, though its customs authority still requires legalization for certain commercial document categories.
Saudi Arabia: apostille, being a Convention party.
4. Africa
Nigeria: consular legalization, plus the conformity assessment programme.
Kenya: consular legalization, plus pre-export verification of conformity.
Egypt: consular legalization with translation.
Algeria, Morocco, Sudan, Ethiopia: consular legalization with Arabic or French translation.
South Africa: apostille, being a Convention party.
5. Asia
Japan, Korea, Singapore, Malaysia, Indonesia, the Philippines, Thailand (from February 2027), Vietnam (following its September 2026 accession): Convention parties or acceding, apostille available.
India: Convention accession but a filed objection, so a Chinese document needs consular legalization.
Bangladesh: consular legalization.
Pakistan: consular legalization, though the FTA certificate has its own form.
6. Europe and the Americas
All EU member states, the UK, Switzerland, Norway, Iceland, Turkey, Russia’s neighbours: apostille, apart from Russia itself, which requires consular legalization.
Latin America: Brazil, Argentina, Peru, Chile, Colombia, Mexico, Uruguay, Paraguay are Convention parties. Cuba, Bolivia, Venezuela and some others are not.
7. The pattern
Apostille applies to the large majority of destinations by trade volume.
Consular legalization concentrates in the Gulf, North Africa, South Asia and Russia.
The concentration matters because those are markets where trade is growing and where the documentation difficulty adds to the other difficulties.
8. The single table an exporter needs
A table with one row per destination and four columns: Convention status, apostille available, translation required, additional certificates required.
The table is specific to the exporter’s markets, and it takes an afternoon to build.
9. Common errors
Assuming a region is uniform
The Gulf is not: Bahrain and Saudi Arabia take apostilles, Kuwait and Qatar do not.
Assuming the Convention status settles it
The UAE shows that a party state can still require legalization.
Assuming translation is not needed in apostille destinations
Brazil and Mexico both require translation.
Using a table from a previous year
Convention status changes. Thailand and Vietnam both moved recently.
10. Closing view
The destination table is the single most useful document an export documentation function can maintain.
Everything else — the process, the timeline, the cost — follows from it.
*This article is based on the Hague Apostille Convention status table and the consular authentication guidance published by China’s Ministry of Foreign Affairs, updated October 2026. Exporters should confirm requirements with each destination authority.*