The vocabulary, in plain English
Cross-border trade runs on terms that are precise in one language and approximate in the other. These are the ones that cost people money when they are misunderstood — defined properly, with the Chinese original where it matters.
Company records
- Business licence 营业执照
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The certificate issued to every registered Chinese company, carrying its name, code, legal representative, capital and permitted business scope.
Issued by the local market-regulation authority. The physical certificate is what suppliers photograph and email; the authoritative version is the record behind it on the national registry. A licence image proves nothing until it matches that record, and comparing the two is the single cheapest check in China sourcing.
- Unified Social Credit Code 统一社会信用代码
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The 18-character identifier that uniquely identifies a registered Chinese organisation. Simultaneously its registration number and tax number.
Introduced by the 三证合一 reform, which merged the old business, tax and organisation-code numbers into one. It never changes, and it is the key to looking up any Chinese company. Characters three to eight encode the registering administrative division, so the code quietly tells you where a company is actually registered.
- Business scope 经营范围
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The controlled field on a Chinese business licence stating what activities the company is permitted to carry on.
Not free text — it is registered, published, and can only be changed by filing. This makes it the most reliable signal of whether a supplier is a manufacturer or a trader: a manufacturer’s scope contains 生产 or 制造 for the relevant goods, a trader’s contains only 销售 or 贸易. A company operating outside its registered scope is exposed to penalty, which is also why we publish our own.
- Legal representative 法定代表人
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The individual registered as able to bind a Chinese company. Not the same idea as a director or a CEO.
Chinese law vests binding authority in one named natural person, recorded on the licence and the registry. Their signature and the company chop are what make a contract stick. If the person signing your agreement is not the legal representative and is not carrying a documented authorisation, you have a problem that is much cheaper to find now than later.
- Abnormal operations list 经营异常名录
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A public listing applied to companies that failed to file an annual report or could not be reached at their registered address.
Visible on the national registry alongside the company record. A listing is not automatically fatal — administrative slips happen — but it always needs explaining before money moves, because the two most common causes are a company that has stopped filing and a company that no longer exists where it says it does.
- Company chop 公章
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The official seal of a Chinese company. In practice it carries more weight than a signature.
A document bearing the company chop is generally taken as an act of the company. Chops are registered with the Public Security Bureau, and companies typically hold several — a company chop, a contract chop, a finance chop, an invoice chop and a legal-representative chop. Control of the chop is control of the company, which is why chop custody is a real governance question rather than an administrative one.
Trade & tax
- Fapiao 发票
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The official tax invoice in China. A receipt is not a fapiao and does not have the same effect.
Fapiao are issued through the state tax system, and they are how expenditure is recognised for Chinese tax purposes. For a foreign buyer they matter mostly as a signal: a supplier who cannot or will not issue a fapiao for a domestic transaction is telling you something about how they operate. Increasingly issued in fully digital form.
Market entry
- WFOE 外商独资企业
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Wholly Foreign-Owned Enterprise — a Chinese limited liability company owned entirely by foreign investors.
The usual vehicle when a foreign business genuinely needs to operate in China: invoicing domestically in RMB, holding inventory in its own name, employing staff directly. It carries the full compliance load — bookkeeping, monthly and annual filings, an annual report and audit — and deregistration commonly takes the better part of a year. Register one when a specific trigger requires it, not because it feels like the serious option.
- Negative list 负面清单
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The published list of sectors where foreign investment in China is restricted or prohibited. Anything not on it is open.
China regulates foreign investment by exception: the list names what is restricted, and everything else is treated the same as domestic investment. It is revised periodically and has been progressively shortened, most notably across manufacturing. Checking the current edition is the first step in any market-entry question, because it determines whether the rest of the conversation is even possible.
- Cross-border e-commerce 跨境电商
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The regulated channel through which Chinese consumers buy imported goods directly from overseas sellers.
Lets a foreign brand reach Chinese consumers without a Chinese entity, which is the whole point of it. Platform onboarding standards have tightened and now commonly require an overseas corporate record, an overseas trademark, verifiable production footage and evidence that the business genuinely operates. Requirements change — verify against the platform’s own merchant terms before building anything.
Documents
- Apostille
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A single certificate that authenticates a public document for use in another country that is party to the Hague Convention.
Since China joined the Convention, documents moving between China and other member states no longer need consular legalisation. An apostille authenticates the signature or seal on a document — it says nothing about whether the content is true, and nothing about whether the receiving institution will accept your translation. Those remain separate problems.
- Certified translation
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A translation accompanied by a signed statement of accuracy and, in China, the translating company’s seal.
There is no single international standard, which is the source of most rejections. What matters is the receiving institution’s requirement — a Chinese bank, a registry, a court and an overseas platform may each accept something slightly different. Ask the recipient what they accept before commissioning the translation, not after.
Brand & IP
- CNIPA 国家知识产权局
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The China National Intellectual Property Administration — the authority for trademarks and patents in mainland China.
Trademark applications are filed with CNIPA, and for a foreign applicant must generally be filed through a trademark agency registered with it. Yimi is not a trademark agency: we do class and subclass strategy and read the clearance search, and a registered agency files.
- First to file
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The principle that trademark rights in China go to whoever registers first, largely regardless of prior use elsewhere.
The reason foreign brands lose their own names in China. The pattern is mundane: a brand sends artwork to Chinese manufacturers with a quotation, and files months later once volumes justify the cost. By then a supplier, a distributor or a speculative filer has registered it. File before the first conversation, and register a Chinese-character version as well as the Latin one.
- Subclass 类似群组
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China subdivides the international trademark classes into subclasses, and goods in different subclasses are often treated as dissimilar.
This is why filing "in class 25" is not a strategy in China. A registration covering your product but not the adjacent subclass can leave a gap wide enough for a near-identical mark to be registered alongside you. Class and subclass mapping is a technical exercise, and getting it wrong is expensive to fix.
Customs
- HS code
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The Harmonized System code that classifies a traded product and determines the duty applied to it.
Classification drives everything downstream: the base rate, whether product-specific measures apply, and whether documentation requirements bite. It is the importer’s responsibility and the importer’s liability — a supplier’s suggested code is a starting point, not a defence. Classification itself is work for a licensed customs professional.
- Importer of record
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The party legally responsible for a shipment entering a country — the duty, the declaration and the records.
Normally the buyer, not the supplier and not the marketplace, and the liability follows the role regardless of who arranged the freight. A supplier shipping DDP is offering commercial convenience, not necessarily transferring the legal liability — and often means an unfamiliar third party is named on entries filed against goods you own.
- De minimis
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A value threshold below which imported consignments were admitted without duty and without a formal customs entry.
The relief that built direct-to-consumer shipping from China. It has been withdrawn in the major Western markets, which converted an entire population of parcel shippers into bulk importers overnight — needing HS codes, formal entries, an importer of record and, for the first time, a supplier worth verifying.
- Rules of origin
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The rules determining which country a product legally comes from — decided by where it was substantially transformed, not where it was last shipped from.
Central to any China-plus-one plan. Importing Chinese components, assembling them minimally in a third country and exporting them as that country’s origin does not achieve what buyers hope, and misdeclaration exposure falls on the importer of record. A genuine transformation can be evidenced; a nominal one cannot.
Compliance
- EU Responsible Person
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An economic operator established in the European Union, named for a consumer product and holding compliance responsibilities for it.
Must be established in the Union, holds the technical documentation, cooperates with market-surveillance authorities and is identifiable on the product or its packaging. Products placed on the EU market generally require one. The practical bottleneck is rarely finding a person to hold the role — it is getting the Chinese factory to produce a technical file.
- Supply-chain due diligence
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The documented process of identifying, assessing and mitigating risks in a supply chain — increasingly a legal obligation rather than good practice.
Forced-labour, corporate sustainability and product-safety regimes now require mapped, monitored and documented supply chains. In China this collides with tightened rules on data and foreign-directed investigation, so the file has to be built from lawful, disclosable sources — public registers, verification with issuing bodies, and consented site visits. A file assembled covertly cannot be shown to the party who demanded it.
Missing a term? Tell us and we will add it. The longer explanations live in answers, and the procedural walk-throughs in guides.
Know the words. Want the work done?
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