International collections
Collect a Debt from a Company in China
Updated 2026-10-24
Collecting from a company in mainland China depends mostly on amicable work by a Mandarin-speaking partner in China: confirming the registered Chinese name and credit code, sending a formal demand in Chinese and negotiating with the legal representative or finance team. Enforcing a U.S. judgment in China is difficult and uncertain, so if negotiation fails, options such as suing in China or arbitration should be reviewed with Chinese counsel.
| Language | Mandarin Chinese (simplified characters) |
|---|---|
| Currency | Renminbi (CNY); outbound payments are subject to foreign exchange controls |
| Legal system | Civil law system with its own court structure and arbitration institutions |
| Enforcing a U.S. judgment | Difficult and uncertain; no treaty with the U.S., recognition depends on reciprocity and has been granted only in limited cases |
| Company ID | Unified Social Credit Code on the business license; the registered Chinese name is what counts |
| Typical amicable timeline | Varies widely; often 60 to 120 days or more |
Start with the right legal name
Many U.S. suppliers know their Chinese customer only by an English trade name. That name usually has no legal standing. The entity that owes you money is the one registered in Chinese characters, with an 18-character Unified Social Credit Code on its business license. Before any demand is sent, our partner matches your paperwork to that registered entity and checks that it is still active.
This step also catches a common problem: the company that placed the order is not always the company that received the goods or made earlier payments. Trading companies, related entities and agents can all appear in the paper trail. Knowing exactly who signed the contract shapes every later step.
How we approach Chinese debtors
- Verify the registered Chinese name, credit code, legal representative and registered capital
- Check public records for litigation, enforcement listings and abnormal operation notices
- Send a formal demand in Chinese through an in-country partner
- Follow up by phone and messaging apps used for business in China
- Negotiate payment or a written repayment plan, including how foreign exchange will be handled
- Give you a frank assessment of legal options if the debtor will not pay
Why U.S. judgments are hard to use in China
There is no treaty between China and the United States on the recognition of court judgments. Chinese courts apply reciprocity, and for many years that meant U.S. judgments were rarely recognized. A small number of cases since 2017 have recognized U.S. money judgments, and commentators describe a trend toward a more open approach to reciprocity. Even so, outcomes remain uncertain, proceedings are slow and the debtor can raise defenses based on service, jurisdiction and public policy.
Because of this, a U.S. judgment is rarely the best tool for collecting from a mainland Chinese company with no assets in the United States. Alternatives worth discussing with Chinese counsel include suing the debtor directly in a Chinese court, or arbitration if your contract contains an arbitration clause. China is a party to the New York Convention, so foreign arbitral awards have a recognized enforcement route, subject to the convention's grounds for refusal.
Documents that carry weight in China
- Signed contract, ideally bearing the company seal (chop) of the Chinese entity
- Purchase orders and pro forma invoices referencing the registered name
- Shipping documents and proof of delivery
- Payment records showing earlier transfers from the debtor
- Messages or emails acknowledging the balance
- Chinese translations of key documents if a lawsuit is likely
Setting realistic expectations
Results in China depend heavily on whether the debtor wants to keep trading with foreign suppliers, whether it is still solvent and how clearly the debt is documented. A debtor that values its reputation or its supply chain will often negotiate. A company that has stopped operating, or has moved its business to a new entity, is much harder to recover from.
Payment logistics also matter. Chinese companies need supporting documents to remit foreign currency abroad, so a settlement should spell out the invoices being paid and the bank details to avoid delays at the remitting bank.
China is 12 or 13 hours ahead of U.S. Eastern time, depending on daylight saving. Our partners work Chinese business hours and report back overnight, so you see progress at the start of your day.
Frequently asked questions
Can I enforce a U.S. court judgment in China?
It is difficult and uncertain. There is no U.S.-China treaty, Chinese courts apply reciprocity, and only a limited number of U.S. judgments have been recognized. Ask Chinese counsel whether suing in China or arbitration is a better route.
Why does the company chop matter?
In China, the company seal is the usual way an entity signs contracts. A contract bearing the chop of the registered entity is much stronger evidence than one signed only by an individual.
What if my customer used an English name only?
Our partner matches the English trade name to the registered Chinese entity using the business license, credit code and transaction records. Without that match, a demand or lawsuit may not reach the right company.
Do you collect from Hong Kong or Taiwan companies too?
Yes, but they are separate legal systems with different rules. This page covers mainland China. Ask us about Hong Kong or Taiwan files and we will explain the differences.