The last block on a PI is often copied from the last PI. “English law, courts of London.” “California law.” Or nothing at all. None of those lines is decoration. When the deposit is gone and the goods are wrong, that block decides which rules apply and where you have to argue. Leaving it blank does not give you your local courthouse. It usually leaves you closer to the factory than you think.
This piece is what those two sentences are for — not a forum-shopping brief.
1. Two separate choices, not one slogan
Write them as two lines:
- Governing law — which country’s contract rules interpret the PI
- Forum — which court or arbitration body hears the fight, and in which language
A PI that says “disputes shall be settled friendly” has neither. A PI that names New York law but is silent on forum still leaves you arguing about where to file. A PI that names a Chinese court but an English governing law asks a local judge to apply a foreign statute they may not use in practice. Pick pairs that can actually sit together.
2. Why “my country’s court” is often a paper victory
If the supplier, the workshop, the mold, and the bank account are all in mainland China, a judgment from your home court can be expensive to use there. You may win on paper and still be unable to touch the deposit or the tool. That does not mean Chinese law is automatically “better.” It means the clause should match where the assets sit, or you accept that the clause is for leverage and insurance files, not for easy enforcement.
Arbitration is the usual middle: a named commission, a named city, a named language. Name the institution. “Arbitration in China” is not a seat. “CIETAC Beijing, English language” is a seat. If you name an institution whose rules you have never read, you will meet those rules for the first time when you are already late.
3. Language of the contract is a third line
If there is an English PI and a Chinese stamp version, say which text controls when they differ. Courts and commissions in China work in Chinese. An English-only PI will be translated in the fight, by someone you did not choose, at the moment the wording is already contested. If you need both languages, produce them together and state the controlling version. Do not assume the English email chain overrides a stamped Chinese page.
4. What belongs on a short PI — and what does not
On a one-page order, three lines are enough if they are specific:
- this PI is governed by [law]
- disputes go to [named court or named arbitration institution and city]
- the [English / Chinese] version controls
Do not paste a four-page dispute schedule from a master supply agreement onto a $12,000 first order unless both sides will actually sign it. An overbuilt clause that the factory strikes in WeChat is worse than a short clause that stays on the page.
The bottom line
Governing law, forum, and controlling language are not footer decoration. If they are blank, copied from the wrong country, or split in a combination no one can run, you will spend the dispute arguing procedure. Write three sentences that match where the factory and the money sit — or accept that you bought a clause you cannot use.
If you need the governing-law, forum, and controlling-language lines written into the PI in English and Chinese, I can prepare the clause and issue a stamped set under our bilingual translation company seal when you need one. See what this covers.
Forum and governing-law choices have enforcement consequences that depend on the facts and on local procedure. This article is general sourcing guidance, not legal advice. Have counsel review the clause before you rely on it for a large order.