Gulf Buyers and Chinese Suppliers: Where Your Judgment or Award Can Actually Be Enforced

The question usually arrives after the decision has already been made: "We have a judgment from our court in Dubai against the Chinese factory. How do we collect?" By then the answer depends on two things chosen months earlier, often without much thought: the kind of decision you hold, and where the supplier keeps its money.

This note sets out the routes for a buyer in the Gulf. It is general information. The right route for a particular contract depends on its wording and on the supplier's assets.

Start with the assets

A Chinese manufacturer's bank accounts, receivables, equipment and property are almost always in mainland China. A decision from any court or tribunal outside China only turns into money once a Chinese intermediate people's court agrees to recognise and enforce it. So the real question is which foreign decisions Chinese courts will enforce, and how.

If the supplier has assets outside China, for example a Hong Kong trading company that receives payments or goods held in a Gulf free zone, you may be able to act on them locally. That is worth checking before anything else.

Route 1: an arbitration award

China and all six Gulf Cooperation Council states are parties to the New York Convention on foreign arbitral awards. A Chinese court will enforce an award made in the UAE, Saudi Arabia, Qatar, Kuwait, Bahrain or Oman under the Convention, subject to its limited grounds for refusal: no valid arbitration agreement, a party not given proper notice or a fair chance to present its case, the tribunal going beyond what was submitted, an irregular procedure, or a conflict with Chinese public policy.

The application goes to the intermediate people's court where the supplier is domiciled or where its property is (Civil Procedure Law art. 304). In practice, awards fail in China for ordinary reasons: the award names the wrong Chinese company, the supplier was never properly notified, or the arbitration clause was written in a way Chinese law treats as unclear. Our separate note on a US award that failed in China because of a wrong entity name shows how it happens.

Route 2: a Gulf court judgment

Court judgments are harder. A Chinese court recognises a foreign judgment only under a treaty or on the basis of reciprocity (Civil Procedure Law arts. 298 and 299).

Treaties. China's judicial assistance treaties with the United Arab Emirates and with Kuwait both provide for recognition and enforcement of each other's court judgments in civil and commercial matters (art. 17 of each). Each lists grounds for refusal, including a judgment that is not final or enforceable, a court without jurisdiction, a claim contrary to the law or public order of the state asked to enforce, and a default judgment given without proper summons (art. 21 of each). The Kuwait treaty covers only judgments given after it came into force, and confirms that arbitral awards are enforced under the New York Convention (art. 28). A China–Saudi Arabia agreement signed in 2022 and ratified by China in 2025 also covers court judgments (art. 19); check that it has entered into force before relying on it. China has no such treaty with Qatar, Bahrain or Oman, so reciprocity applies there.

Reciprocity. For other states, a Chinese court asks whether a Chinese judgment would, in similar circumstances, be recognised by the courts of the country that gave the judgment. Since 2022 the Supreme People's Court has told lower courts they may find reciprocity where the other country's law would allow a Chinese judgment to be recognised, even if no Chinese judgment has yet been tested there (2021 Conference Minutes on Foreign-Related Commercial and Maritime Trials, art. 44).

Grounds for refusal. Even where a treaty or reciprocity applies, a Chinese court will refuse recognition if, under Chinese law, the foreign court had no jurisdiction, the supplier was not properly summoned or given a fair chance to be heard, the judgment was obtained by fraud, a Chinese court has already ruled on the same dispute, or recognition would breach basic principles of Chinese law or public interests (Civil Procedure Law art. 300).

Notice is the weak point for many Gulf judgments against Chinese companies. Serving court papers on a company in China has to follow the Hague Service Convention or the relevant treaty. Papers sent by courier or email, or served by publication in the Gulf, may not count.

Route 3: sue in China

Suing the supplier directly in a Chinese court avoids the recognition step. A Chinese judgment is enforced by the same court system that holds the supplier's assets, and the court can freeze accounts at the start. The trade-off is that you litigate in Chinese, under Chinese procedure, often in the supplier's home city. For many disputes about goods, prepayments or tooling, this is the quickest route to money, provided your contract lets you bring the case there.

What to put in your contract now

1. Pick one route and write it clearly. An arbitration clause naming one institution and one seat, or a clause giving jurisdiction to a named Chinese court. Avoid "arbitration or court" clauses, which Chinese courts may treat as invalid.
2. Name the right Chinese entity. Use its full registered Chinese name and its unified social credit code in the contract.
3. Agree on service. Give an address and an email in China for notices and for service of proceedings, and make that agreement express.
4. Think about interim relief. If you may need to freeze the supplier's accounts before an award is made, the seat matters. See our note on choosing a seat for Gulf buyers.

Part of my guide to China legal work for Gulf buyers.

If you buy from China for a business in the Gulf, send me your contract or the dispute in outline and I will tell you where the pressure points are. Discuss a supplier dispute from the Gulf →