1. The role of the notary
Not every Chinese document can be sent directly for an apostille.
Where a document is not already a certified public document on its own, a notary has to act first.
2. The common misjudgement
Exporters read the Convention as universal, apostille any paper bearing a seal, and discover the rejection at the receiving authority.
3. The two-step approach
First step
Ask what kind of document this is: a document issued by an authority, or a private document requiring notarisation.
Second step
Ask what the receiving authority accepts: an apostille on the authority document, or an apostille on a notarial certificate.
4. The judgement question
The Chinese notary is the practical gateway to the apostille.
Whether the notarial act the destination accepted was correct is a separate matter.
5. The scenario
An exporter sent an uncertified copy of its business registration document.
The apostille authority refused because it was not a certified public document.
6. The lesson
The apostille is a certificate that attaches to a specific document and states facts about it.
7. The checklist
Is the document an authority-issued certificate.
If yes, is the certified copy available.
If not, is a notarial certificate needed.
8. Closing view
The task is to obtain a certified public document.
The apostille then attaches to it.
*This article is based on the Apostille Convention and Chinese notarial and authority certification practice.*