1. Why the question matters
The apostille is applied to a notarised document, not to a self-produced one.
So the document first has to be notarised in the form the destination’s authority requires.
2. For a formal filing
Trade licence and registration documents, notarised, apostilled.
3. For a commercial transaction
A certified copy of a signed contract, with the notary certifying the copy and the signature.
4. What the notarial certificate must say
The notary’s certificate should describe the act performed:
That the signatory appeared and signed in the notary’s presence.
That the copy conforms to the original.
That a fact was witnessed.
5. The scenario
An exporter apostilled a contract copy where the notarial certificate said the copy conformed to the original, and the registered representative signed outside the notary’s presence.
The destination registry queried it. The exporter had believed the notarisation sufficiently established the signature.
6. The gap
Certifying a copy does not certify the signature, and vice versa.
7. The check
Ask the destination’s authority, or the importer, what the document needs to establish.
Then tell the notary.
8. Closing view
Notarial certificates are precise instruments.
Saying the wrong thing, accurately, is still the wrong thing.
*This article is based on Chinese notarial practice and the Apostille Convention.*