1. The US and the Convention
The United States is a party to the Apostille Convention.
For Chinese documents destined for the United States, an apostille issued in China replaces consular legalization.
China’s accession took effect in November 2023, so the two-way route has been available since then.
2. Who issues US apostilles
The United States issues apostilles at the state level, not federally, for documents executed under state law.
The Secretary of State of each US state issues apostilles for documents notarized or issued under that state’s authority.
The US Department of State issues apostilles for federal documents.
This matters for documents going the other direction: a US document for use in China needs the apostille from the correct US authority.
3. Chinese documents for US use
Common cases.
Business licence, for US registration, banking or litigation.
Powers of attorney, for US legal or commercial matters.
Company registration documents.
Contracts.
Academic and civil documents.
The process: notarization, then apostille from the Chinese foreign ministry or an authorised local foreign affairs office.
Translation into English is generally required, and the translation should be certified.
4. Translation practice
US authorities and courts require documents in English.
Certified translations are generally required. The question of who may certify varies.
Federal and state court practice often requires a certification by the translator stating competence and accuracy, rather than certification by a notary.
For commercial purposes, a certified translation alongside the apostilled original usually suffices.
Confirm the specific requirement of the receiving body, particularly for court proceedings.
5. The corporate document question
A US entity receiving Chinese corporate documents, for a state registration, a bank account or litigation, typically wants:
The business licence, apostilled and translated.
Company registration documents.
A power of attorney, if an agent acts.
A certificate of good standing, where the Chinese regulator issues one.
Note that Chinese companies are not registered at the state level the way US companies are, so a US counterparty expecting a “certificate of good standing” may need an explanation of what the Chinese equivalent is.
6. Documents for litigation
Where Chinese documents are used in US litigation, additional requirements apply beyond the apostille.
Authentication for court purposes may require compliance with federal rules on foreign official documents, which provide routes beyond the Convention.
Depositions and evidence from China for US proceedings involve the Hague Evidence Convention arrangements.
These are matters for the litigating parties’ counsel, not for the exporter’s document process.
7. Timing
Notarization: a few days.
Apostille: typically a few days.
Translation: a few days.
A full cycle runs one to two weeks.
8. Common errors
Running the consular route
The US is a party. The apostille applies.
Translation not in the form the court requires
Court practice differs from commercial practice.
Sending a US document to a Chinese authority without an apostille
US documents for Chinese use need an apostille from the correct US authority, or consular legalization if that route applies.
Confusing state and federal apostille
State-issued documents get state apostilles; federal documents get federal apostilles.
Assuming a Chinese company has a US-style good standing certificate
The equivalents differ.
9. Closing view
The US route is straightforward under the Convention.
The complications sit at the edges: court proceedings, translation form, and the mismatch between US and Chinese corporate document terminology.
*This article is based on the Hague Apostille Convention and the consular authentication guidance published by China’s Ministry of Foreign Affairs, updated October 2026. Users should confirm requirements with the receiving US authority.*