Chinese translation with notarial certification

A notarised Chinese translation is a bridge between two very different systems. In China the notariat is a state institution that turns every document intended for abroad into a notarial certificate of its own format; in Georgia the notary is a private practitioner who certifies the translator's signature. Since November 2023 these two systems are connected by the apostille, but each side keeps its own expectations about the form of the translation. This page explains how to prepare a Georgian document so that an authority in Beijing, Shanghai or Guangzhou accepts it, and how to render a Chinese notarial certificate so that a Georgian authority treats it as a fully fledged document.

Two notariats: what each certifies

When certifying a translation the Georgian notary does not personally check linguistic accuracy; they confirm that the translation was done by a translator registered with them, whose qualification in the Chinese-Georgian pair has been checked in advance, and that the signature is genuine. Such a document is a public act under Georgian law, with a registration number, and its authenticity can be verified at any time.

A Chinese notarial office (公证处) performs an entirely different function: it certifies a fact or a document, not the translator's signature. When a Chinese citizen needs a birth certificate abroad, they go to the notarial office, where the notary certifies the fact of birth, attaches a translation (often English) to the certificate and binds the whole package with a seal. It is precisely this "notarial booklet" that comes to Georgia, and for the Georgian recipient it is important to understand that in it the notary does not "certify a copy" but confirms the fact itself, which gives the document higher legal force.

The apostille for China: what changed and what did not

Until 7 November 2023 a Georgian document intended for China went through three steps: the notary, the consular department of the Ministry of Foreign Affairs, the Chinese embassy in Tbilisi. Today this route has shrunk to one stamp: the apostille from the Public Service Hall, which the Chinese side recognises directly. For a document coming from China to Georgia the apostille is attached by China's Ministry of Foreign Affairs or an authorised provincial foreign affairs office, often through the same notarial office where the certificate was made.

What has not changed is the attitude of Chinese authorities towards the translation. The apostille confirms that the Georgian notary's seal is genuine; whether a specific Chinese authority will accept a Georgian translator's Chinese text is decided by that authority itself. In practice three scenarios occur: the authority accepts the apostilled notarised translation in full; the authority requires a translation by an agency licensed in China with a translation seal; the authority requires a translation certified at a Chinese notarial office. For each scenario we prepare the document differently, so clarifying the recipient is the first step of the order.

China direction: which document to which authority

• Exit-entry administration of the Public Security Bureau: marriage and birth certificates, criminal record certificate for a residence permit
• Foreigners' work permit service: diploma, certificate of work experience, criminal record certificate
• Civil Affairs Bureau: certificate of marital status for marriage registration
• University admissions offices and CSC: diploma, transcript of grades, medical form
• Administration for Market Regulation: a Georgian company's registration documents for a representative office or joint venture
• Courts and arbitration commissions: power of attorney, corporate documents, evidence

Each of these authorities has its own internal practice, and the same document, for example a criminal record certificate, is accepted in one city with an apostilled Georgian translation, while in another a local retranslation is required. We keep track of this practice and advise the client on what experience we have with a specific province, though the final answer must always come from the receiving authority.

Georgia direction: translation of a Chinese notarial certificate

Most personal documents coming from China to Georgia are in the form of a notarial certificate and follow the same structure: a title page with the name of the notarial office, the text of the certificate in Chinese, often an English translation, a copy of the attached document, the notary's seal and signature, the apostille. A Georgian authority requires a translation of this whole package, not of one page only.

Two rules that we strictly observe in these translations. First: we translate from the Chinese text, not from the English attachment. The English translations of Chinese notarial offices are often schematic, sometimes leave out the text of seals, sometimes simplify details, and a notarised Georgian translation must match the original, not an intermediate version. Second: every element of the certificate, the name of the notarial office, the certificate number (公证书编号), the notary's name, the text of the seals and the fields of the apostille, is reflected separately in the translation, so that the Georgian employee sees the structure of the document and its origin in full.

Typical Chinese notarial certificates and their Georgian purpose

• Notarial certificate of birth (出生公证): for Georgian citizenship, residence or inheritance cases; includes the parents' names, which is essential for the Georgian registry
• Certificate of no criminal record (无犯罪记录公证): for a residence permit, sometimes for work; the Chinese side draws it up on the basis of a Public Security Bureau certificate
• Certificate of being unmarried (未婚公证): for marriage registration in Georgia
• Certificate of marriage (结婚公证): for family reunification and residence
• Certificate of education (学历公证 and 学位公证): for diploma recognition; often a separate certificate for education and a separate one for the degree
• Certificate of kinship (亲属关系公证): for taking a child abroad or family matters, a document characteristic of the Chinese system that has no Georgian equivalent and needs explanation in the translation

Corporate documents in Chinese-Georgian business

Registration of Chinese investment in Georgia or a Georgian company's representative office in China requires a package of corporate documents where notarisation is needed at every stage. The Chinese business licence (营业执照) is a one-page document that contains at once the company's name, the unified social credit code (18 digits), the legal representative (法定代表人), the capital and the business scope. The last is legally restrictive in the Chinese system, and its exact rendering in the translation matters for the Georgian notary and registry.

The "legal representative" is the central figure of Chinese corporate law, to which the "director" of Georgian law does not exactly correspond: this person acts on the company's behalf by force of law, not by power of attorney. In the translation we keep this term and add an explanation in brackets, so that the Georgian lawyer correctly assesses this person's authority. In the opposite direction, when translating a Georgian extract from the register of entrepreneurs into Chinese, the Georgian "director" must be written in Chinese terminology so that the Chinese authority attributes representative authority to them.

Power of attorney in Chinese notarial practice

The power of attorney (授权委托书) is the most frequently certified document in relations with China: a Georgian company grants a Chinese representative authority in customs, court or registration matters, while a Chinese investor grants a Georgian lawyer authority to register a company in Georgia. Chinese courts and authorities expect a specific structure from a foreign power of attorney: full details of the authorised person, an exhaustive list of powers, a term, signature and seal, apostille. The "general" wording of a Georgian notarial power of attorney is often insufficient for the Chinese side, so before the translation we also give advice on the wording of the document. When translating a Chinese power of attorney into Georgian the attention is on the seal: in the Chinese system a power of attorney is given force by the company seal, and the text, type and even colour of the seal (the company seal is red and round) are described in the translation.

Certification of educational documents in both directions

For the Chinese Government Scholarship and university admissions offices a Georgian diploma and transcript of grades are prepared with an apostille and notarised translation. Chinese admissions committees often ask separately for the diploma and separately for the transcript, each with its own apostille, and from a final-year bachelor's student who does not yet have a diploma, a university certificate of expected graduation. The Georgian 100-point or 10-point grading system formally resembles the Chinese 100-point system, but the pass threshold and the categories differ, so we attach an explanatory note to the translation of the transcript.

In the opposite direction, for recognition of a Chinese diploma in Georgia two Chinese notarial certificates come, of education (学历公证) and of degree (学位公证), sometimes a third, of the transcript. Added to this is the verification report from China's education verification centre, which the Georgian authority asks for increasingly often. We translate this package with one terminology base, so that the university's name, the speciality and the degree are written identically in all documents, because it is precisely a discrepancy that becomes the most frequent reason for refusal of recognition.

Notarised translation of medical documents

For a work and study visa to China the foreigner physical examination form is mandatory, which is filled in either in China or in Georgia, in the format set by the Chinese side, and then submitted with an apostille and translation. This form is a medical and administrative document at once: laboratory values, the doctor's conclusion, the clinic's seal and signature, everything is translated. Medical documents coming from Chinese clinics to Georgia, the discharge summary (出院小结), diagnosis certificate (诊断证明) and test results, are translated for a Georgian doctor or an insurance company and, in the case of a court or insurance case, notarised. The translation of Chinese medical documents is checked by an editor with a medical education, who compares clinical logic and terminology.

Customs and export documents

When exporting Georgian wine, hazelnuts and mineral water to China, Chinese customs and the importer require a package of documents: certificate of origin for the preferential rate of the free trade agreement, certificate of analysis, health certificate, Chinese version of the label, the manufacturer's registration data. Part of these documents is accepted in English, part must be in Chinese, and which one often depends on the practice of the specific port and importer. Our approach is to translate customs documents in the official terminology of Chinese customs and notarise them when needed, and to adapt the Chinese version of the label to the requirements of the Chinese food labelling standard, because it is precisely a non-compliant label that becomes the most frequent reason for a shipment's delay.

Regular clients and contract service

For companies that work with China constantly, wine exporters, construction contractors, logistics operators, car importers, we have a separate format: contract service with a permanent translation team, the company's terminology base and fixed deadlines. In such cooperation notarisation is done in packages, several documents in one visit, and attaching the apostille is planned on a monthly schedule. This format is especially effective when the same type of document, for example the certificates of every batch, repeats regularly: the terminology and format are already approved, and the translation requires only checking the variable data.

Notarial or agency certification

Not every Chinese translation needs notarisation. A wine presentation for a Chinese importer, a technical catalogue, business correspondence, a website, a tourist brochure are translated without certification or with the agency's stamp. Agency certification is often enough for a Chinese company's internal needs, for the informational version of tender documents and for a university's preliminary assessment. Notarisation is needed wherever the document causes a legal consequence: a state authority, court, bank, registry, customs. If you are not sure, ask us: on the China direction we have enough experience to say what is sufficient, and we will not offer you anything superfluous.

Frequent mistakes that become the reason for refusal

Experience of rejected translations on the Chinese direction shows several recurring reasons: translating from the English attachment instead of the Chinese original, because of which seals and details were lost; writing a Chinese name differently from the passport's pinyin; wrong conversion of numbers from the 万 and 亿 system; confusing the date format; wrong choice of traditional and simplified characters for the target jurisdiction; incomplete translation of the business scope in the business licence; omitting the fields of the apostille. Every one of these points is on our checklist. If you approach us with a translation by another provider that was rejected, we first establish the exact reason and correct only the necessary part.

Process and deadlines

You upload the document on the website, indicate the target authority and jurisdiction (mainland, Hong Kong, Taiwan, Singapore), we assess and start. A standard personal document is ready in one working day, express in 1-2 hours; a multi-page notarial certificate or a corporate package with an individual deadline. Attaching the apostille at the Public Service Hall is done within the order. Physically bringing the original is needed only if the apostille is to be attached to the original or the authority requires the translation to be bound to the original. All documents are processed within a confidentiality agreement.

Frequently asked questions