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INDIVIDUALS & FAMILY · CHINESE LEGAL GLOSSARY REVIEWED SEP 2026
附加证明书

Apostille

The certificate used under the Hague Apostille Convention to authenticate the origin of a public document for use in another Convention member, replacing consular legalization between members.

CHINESE附加证明书
PINYINfujia zhengmingshu
PREFERRED ENGLISHApostille
AREAIndividuals & family
WHAT 附加证明书 MEANS

What 附加证明书 means

The Convention took effect for China on 7 November 2023. A Chinese Apostille verifies the authenticity of the final signature or seal on the public document; it does not certify the truth of the document’s substantive contents.

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Why the role matters

Cross-border corporate, family, immigration and litigation matters should first check whether both jurisdictions are Convention members. Non-member routes may still require traditional consular legalization.

CONTEXT

Where you see the term

ContextWhat it means there
Corporate documentsBoard or registry documents used overseas.
Family / civil statusBirth, marriage or other public records.
Litigation / immigrationPublic documents submitted to foreign authorities.
TRANSLATION NOTE
文/A

Translation note

附加证明书 is China’s official Chinese term for an “Apostille”. It should not be described as full consular legalization.

AUTHORITY

Primary legal basis

PRIMARY AUTHORITY

Hague Convention Abolishing the Requirement of Legalisation for Foreign Public Documents; PRC MFA implementation guidance

China has issued Apostilles since 7 November 2023 for Convention use.

China has issued Apostilles since 7 November 2023 for Convention use.

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ILLUSTRATIVE EXAMPLE

Example

A Shanghai company needs a notarized corporate document for use in France. If the document is a public document within the Convention’s scope and the Convention applies between China and the destination jurisdiction, an Apostille can replace the previous consular-legalization chain; otherwise, another authentication route may still be required.

SOURCES AND REVIEW

Primary authorities.

Last source check
18 Sep 2026
MAINTAINED BYChina Legal Portal Editorial
LAST REVIEWED
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