Germany Certificate of Origin for Use in China
The Situation
A certificate of origin issued in Germany has to be used in China. The instinct is to send the original to China and sort it out there.
That instinct costs an international courier round trip, because China does not authenticate foreign documents. The authentication has to happen in Germany, before the document travels.
What Actually Went Wrong
Chinese notaries cannot authenticate a foreign original. They can notarize a translation of it, which is a different act, and that act does not substitute for authentication abroad.
The correct sequence is two-stage: an Apostille issued in Germany, since both it and China are parties to the Convention, then a Chinese translation notarized as required by the receiving Chinese authority.
How It Was Resolved
Obtain the authentication in Germany first. Then have the document translated into Chinese by an agency the receiving Chinese authority accepts, and have that translation notarized in China where required.
The two stages are normal and expected. Merging them, or reversing them, is what causes rework — and rework here means another courier leg in each direction.
The General Rule
Foreign-to-China work inverts the usual sequence, and that inversion is the whole lesson.
For Germany specifically: German authorities require a certified translation by a translator sworn before a German court, not any translation agency. The same standard applied to a certificate of origin going the other way does not carry over, because the two directions are governed by different receiving systems.
Check These Before You Submit
- Get the Apostille in Germany first
- Do not send an unauthenticated original to China
- Use a translation agency the Chinese receiving authority accepts
- Budget two international courier legs
Legal Basis
Hague Apostille Convention of 5 October 1961; China in force since 7 November 2023.