Direct answer

A foreign PDF is not a notary exhibit — apostille (or legalisation) plus translation is the usual gate.

Since China joined the Apostille Convention, many public documents from other contracting states use an apostille instead of consular legalisation. Death certificates, court orders, notarial kinship acts and some powers of attorney are in that world. The PRC notary still wants a Chinese translation and may reject the wrong document type (a hospital letter is not a civil death certificate). Non-contracting states still use legalisation. This wiki page is the gate. The long how-to stays on /apostille-chinese-inheritance-process.

The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

01

Is the issuing state in the Apostille Convention with China?

Apostille vs legalisation.

Treaty
02

Is it a public document the notary will recognise?

Civil registry vs private letter.

Kind
03

Chinese translation?

Who may translate locally.

Language
04

Does the notary want originals?

Stapled apostille, not a scan.

Original

Working rule: Map the regulated role before marketing or launch in China.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal
Ask the operating question
Why it changes the route
Scan of a scan
WhatsApp photo of a birth cert.
Will fail.
Guide clone
Rewriting /apostille-chinese-inheritance-process.
Link it.
Apostille on a private will
Treating a lawyer’s draft as a public document.
Wrong path.
Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Document listDeath, kinship, POA, court.
02Issuing countryApostille competent authority.
03Notary’s written checklistLocal extras.
Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Does apostille prove the will is valid?

No. It authenticates the public document (or notarial act), not Civil Code form.

Where is the long guide?

Apostille chinese inheritance process and /cross-border-inheritance-document-checklist.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.