1. Two transactions, two handovers
Getting a document apostilled involves two separate transactions.
The notarization, with a notary office.
The apostille, with the foreign affairs office.
They are distinct relationships, and the handover between them is where documents get stuck.
2. The notarization step
The notary verifies the document and the signatory, then issues a notarial certificate.
The output is an instrument that certifies the document or the signature.
That instrument is what the apostille attaches to.
3. The handover
The notarial certificate goes to the foreign affairs office for the apostille.
Three things can go wrong at this handover.
The notarial certificate is not in an acceptable form
The foreign affairs office has its own requirements for what a notarial certificate must contain.
A notary who does not regularly handle foreign-related work may produce a certificate that omits required elements.
The notary’s signature is not verifiable
The apostille certifies the notary’s signature. The foreign affairs office verifies it against its records.
A newly appointed notary may not yet be registered.
The document is incomplete
Pages missing, or the document presented differs from what the notary certified.
4. What the notary needs to know
Before the notarization appointment, establish:
What the document will be used for.
Which country it is going to.
Whether an apostille or consular legalization follows.
Whether a translation is required, and who should certify it.
A notary who knows the destination can produce a certificate in the right form.
5. The translation sequencing
Translations can be handled three ways.
The notary certifies the translation alongside the document.
The translation is notarized separately.
The translation is certified by a translation service and presented alongside.
Which is accepted depends on the receiving authority.
Where the notary certifies the translation, the apostille on the notarial certificate covers both.
Where the translation is separate, the receiving authority may require it to be separately certified.
6. The timing
Notarization: a few days, depending on appointment availability.
Apostille: typically a few days.
The handover itself, if submitted in person at the foreign affairs office, is same-day.
Some localities allow online submission, which removes a trip but adds processing time.
7. The multi-document case
Where several documents are needed, each is notarized and each notarial certificate is apostilled.
Some localities allow a single notarial certificate covering several documents, which reduces the apostille count.
Confirm whether the receiving authority accepts a combined certificate.
8. Common errors
Notary not told the destination
The certificate may not be in the right form.
Translation arranged after notarization
Reopening the notarization.
Assuming the apostille covers everything
It covers the notarial certificate, which covers what the notary certified.
Not confirming the foreign affairs office’s requirements
Local practice varies.
9. Closing view
The handover between notarization and apostille is a short step and the most common point of failure, because the two offices have independent requirements and neither checks against the other’s expectations.
Telling the notary the destination is the single most useful thing an exporter can do.
*This article is based on Chinese notarial practice and the apostille services provided by China’s Ministry of Foreign Affairs and authorised local foreign affairs offices, updated October 2026.*