How do I publish my mobile app in China? What do I need to provide to complete distribution?

Since the process of distributing mobile apps in China is becoming more and more complicated, we thought it would be the perfect time to summarize the current app distribution procedures.

At the moment, foreign app companies/developers have two options when it comes to distributing apps and games in China.

What are the current options?

Option A is to distribute your app through a local distribution service provider’s account. This option is the faster method of distribution and provides a higher likelihood of success, as Chinese app stores see local accounts as being more trustworthy, which leads to a much smoother approval process. This provider can also do many things on your behalf, making the process smoother and less work for you, answering any questions you might have, and leading you through every step.

Option B is to distribute your app through your own account. This option is the slower method of distribution and offers a smaller chance of success, as local app stores carry out extensive checks on foreign-based accounts, which means more documentation and steps are required. Keep in mind that you must have a Chinese company or a Chinese entity in order to do this.

What materials do I need?

There are a few items you will need to have in advance before you submit your app to your first Chinese app store:

A Chinese Company, Chinese Entity, or Distributor (Android only)

Currently, foreign companies are not allowed to directly publish their apps on Chinese Android app stores. This restriction does not apply to iOS or the Apple App Store in China. 

All foreign app companies must either have a Chinese entity or use an authorized local distributor to publish their mobile apps and games. It’s not enough to have an office in China. Your company must be officially registered as a Chinese company or a Wholly Foreign-Owned Enterprise in China (WFOE). If it is not, then you can simply use a service like AppInChina to publish on your behalf while still retaining full rights to your mobile app or game.

Localized App APK

You will need a version of your app that is appropriate to publish in China. The interface should meet Chinese app norms, and all text should be translated to Simplified Chinese, including buttons and images. You also must ensure that all of its user-generated data is hosted on Chinese servers and that it does not depend on any cloud services, APIs, or SDKs that are inaccessible behind the Great Firewall of China.

Localized App Name, Description, and App Icon

Think carefully about the name you choose for your app because many app stores will require you to list the app with the same name as is registered on your SCC. If you decide to change the name in the future, you would need to go through the process of registering for a new SCC.

Your app’s description needs to be meticulously crafted as well since it will later play an important role in App Store Optimization.

If you would like a professional to review it and ensure that your localization is thorough, AppInChina can help with our comprehensive localization package which includes translation, integration, branding, UI, and testing.

User’s Manual For Your App

Although your app will be reviewed by government regulators, they will not actually open your app to test it. Instead, they will browse through a user’s manual to your app that you will need to provide, which will explain your app and how it functions, along with screenshots and examples.

This need not be as daunting as it sounds. We recommend simply stepping through your app and taking a screenshot of each menu and function. Put the screenshot on one page, and on the opposite page (or below it on the same page) describe what is in the screenshot and how it works. It should be thorough, but the description need not be too long or detailed.

Chinese Software Copyright Certificate (SCC)

All of the major app stores require a Chinese Software Copyright Certificate (SCC). Your certificate has a serial number, and you will need to submit that valid serial number in the form on the store. 

Keep in mind that an SCC is not required to enjoy legal copyright protection of your software in China, but it is extremely helpful in case you need to enforce IP ownership – which is why it is nonetheless required by the Chinese app stores in order to publish your app on their platform.

If you are not using a service provider like AppInChina to get the SCC, you will need the assistance of a Chinese speaker to apply for the SCC on your own with the Copyright Protection Centre of China. The cost will be anywhere between 2200 to 3200RMB, depending on the number of documents involved. 

Please note that a Chinese entity is not a must to apply for an SCC but is highly recommended. If applying as a foreign entity, all documents will need to be translated into Chinese and notarized at the Ministry of Foreign Affairs and the Chinese embassy in your own country. This solution is not only time-consuming (at least 2-3 months) but also likely to be rejected by the top Chinese app stores since they usually don’t accept business licenses from foreign companies as proof of legitimacy.

It takes about one month or less to process an SCC application. With a Chinese partner, it usually takes two weeks or less to receive your approved SCC.

80 pages of source code

As part of the Software Copyright Certificate (SCC) registration process, you will need to submit a chunk of your app or game’s code, defined as “the first 40 pages and last 40 pages”. This is held by the government agency with your SCC to be used as evidence in case you ever need to claim someone else violated the copyright on your software. Its purpose is to protect you.

Some developers are understandably leery of providing the code to their app. Keep in mind that you can choose which part of your app’s code to submit. While we believe there is nothing to fear, we can offer further advice to our clients as to how to comply with this requirement while assuring the protection of their IP.

Additional Documentation and Compliance

• Industry-specific documentation may also be requested to complete distribution depending on the app type (travel, finance, health, etc.).

• Security Assessment Form

Starting in 2019, app developers and publishers must complete a Security Assessment Form in order to publish or update apps on their platforms.

• Personal information collection and protection

With the new personal information protection law coming into effect in November 2021, all apps will need to check the type of information they collect and ensure that it’s communicated clearly in user privacy policy.

Link: Personal Information Protection Law of the People’s Republic of China

• Cross-border data transfer

As stated in the Measures for the security assessment of outbound data (exposure draft), user information collected in Mainland China is required to be stored locally with Chinese cloud serivice providers. Any cross-border transfer is not allowed unless a prior-to-transfer application to the Cyberspace Administration of China is approved.

Link: Measures for the Security Assessment of Outbound Data (Exposure Draft)

If you haven’t sorted out the hosting solution for your application in China, our guide on Integration of a Chinese cloud service for hosting should be able to help you get started.

Keep in mind that in China, legal compliance is the corner stone of any successful business operation involving an online presence. AppInChina has included a compliance assessment in our distribution service so that you don’t fret about the Chinese laws and regulations. We’ll work with you to ensure that your app is compliant before publishing it.

Game License

If your app is a game, you also must receive a game license from the National Administration of Press and Publication (NAPP). This is sometimes referred to as a Game Registration Number (GRN) or ISBN, as an ISBN number is actually issued when your game is approved.

Link: How To Publish A Game In China

IF YOU ARE GOING SOLO…

If you are not using a service like AppInChina to publish your app on your behalf, you will also need the following items: 

• Power of Attorney Letter
• Chinese Business Registration
• Photocopy of Passport (Business registration holder)
• Chinese SIM Card
• Signed Individual App Store Development Statement/Claim Guarantee Letter

Please note that, for games, it is impossible to get a game license without being a Chinese entity. If you are not a Chinese company, or your company does not have a Chinese entity, then you will require a Chinese partner to publish your game.

Link: How To Publish Your Game In China

Submission and Review Process

Once you have all the materials in place, you will need to submit them along with your app or game’s APK to each app store you want to. Unless you use a service like AppInChina, you will need to go through this process once for each app store you submit to – there is no “blanket submission form” to cover them all. 

How long before I am approved?

The entire process for a standard app generally takes between 1-3 months, depending on the complexity of the situation. For a game, it takes 6-12 months to receive your game license approval number. This is why it behooves you to start this process as soon as possible.

From here, you can upload your app’s APK file individually to each app store you wish to publish, along with the supporting documentation you received through this process, which will be verified by each app store prior to posting.

Keep in mind each app store will have their own interface and requirements for this, and most will not have an English-language interface for you to use. This is why, for ongoing maintenance, we highly recommend publishing through a company like ours, which can provide a centralized dashboard for managing your app across all app stores, as well as English-language support as you maintain your app in China.

How we can help?

AppInChina can help you with all of your app and game distribution needs. We can help you procure all the necessary materials to publish your app or game to the top Chinese app stores, and you can manage it all through one-on-one contact with your personal account manager, and through our online client dashboard.