Half a year after China’s new law regarding foreign non-governmental organizations (NGOs) went into effect, many questions remain about the law’s implementation across different regions of China and across different fields of work. To get a better sense of how implementation is proceeding on these fronts, The China NGO Project has compiled and analyzed data released by the Ministry of Public Security (MPS) Foreign NGO Management Office regarding representative office registration and temporary activity filings that took place on or before June 30, 2017.
Registered Representative Offices: Trade-Dominated, Low Numbers in “Sensitive” Areas
As of June 30, 2017, the MPS and provincial-level Public Security Bureaus had officially registered 144 foreign NGO representative offices. (Our information cutoff for this article was July 13, 2017.) For analytical purposes, we have assigned “fields of work” to these foreign NGOs, based on information provided on the MPS website about each NGO’s planned work as well as our own research about general fields of work for civil society internationally. The 27 fields are:
- Aging
- Agriculture
- Animal Protection
- Arts and Culture
- Civil Society Capacity-Building
- Disabilities
- Disaster Relief
- Economic Development
- Education
- Energy
- Environment
- Ethnic Affairs
- Health
- Infrastructure
- International Relations/Exchange
- Labor and Migrants
- Law and Governance
- LGBTQ Issues
- Media
- Poverty Alleviation
- Rural Issues/Development
- Sport
- Technology
- Tourism
- Trade
- Women’s Issues
- Youth
As many registered organizations work in multiple fields, our categorization takes that into account, assigning multiple fields of work when appropriate. In addition, several foreign NGOs have more than one representative office1; for example, U.S.-based Project Hope has offices in Beijing and Shanghai, with the former focused on health and education and the latter working in the health, poverty alleviation, and disaster relief sectors.2
Figure 1
Beijing and Shanghai together granted more than half of the country’s total registrations, with 47 offices and 35 offices, respectively (see Figure 1 above). These two provincial-level municipalities also approved almost all (93 percent) of the 57 registrations that allow offices to operate in the whole of China, with 37 registered in Beijing and 16 in Shanghai. Most representative offices registered in other provinces had more limited areas of work, either in several contiguous provinces or a single province.
Among registered representative offices, trade was the most prevalent sector, with nearly half (67 offices, or 47 percent) of all foreign NGO offices including trade-related issues as part of their work (Figure 2).3 Most of the trade-related foreign NGOs came from the United States (17), South Korea (12), and Japan (11)—indeed, all of Japan’s registered NGO offices and all save one of South Korea’s had listed trade-related issues as part of their work.
Figure 2
The next most common fields of work were education (33; 23 percent) and health (29; 20 percent). Significantly, no foreign NGOs had registered to work in the LGBTQ or media sectors, and there were also very few NGOs registered to work on topics such as law and governance, “women’s issues,” or ethnic affairs.
Figure 3
Most of the representative offices registrations went to organizations from the United States (43 out of the total 144, or 30 percent) and Hong Kong (30, or 21 percent) (Figure 3). Together, the U.S. and Hong Kong (which, like Taiwan and Macau, is subject to the law) accounted for half of all foreign NGO registrations.
Among the NGOs from the United States, the most prevalent sectors of work echoed the overall sector distribution: trade (17) was the most common field of work, followed by education (13) and health (11). More than half of U.S. foreign NGOs (25) were registered to operate in all of China. Beijing was the main location of registration for U.S. NGOs (23), followed by Shanghai (13).
In the latter location, 11 out of 13 U.S. NGOs were registered with the Shanghai Commission of Commerce, which was also the Professional Supervisory Unit (PSU) sponsoring the most representative offices nationwide. The Shanghai Commission of Commerce had sponsored 32 offices as of June 30, 30 of which we labelled as being in the trade sector (most other PSUs had sponsored fewer than 10 offices).
Figure 4
We assigned a similar number of sectors to Hong Kong NGOs as we did to U.S. NGOs, but these sectors were distributed differently. Hong Kong NGOs’ most common fields of work were disaster relief (14 registered offices in this sector) and poverty alleviation (12), whereas the U.S. NGOs included two working in disaster relief and one in poverty alleviation (Figure 4). On the other hand, Hong Kong NGOs had only six offices registered to work on trade, while U.S. NGOs had 17. Additionally, three Hong Kong NGOs were engaged in labor-related work, which as of June 30 saw no U.S. presence at all. Nearly a third of Hong Kong’s NGO registered offices are located in Guangdong (9, or 30 percent), likely due to their close proximity and shared border.Temporary Activities: Hong Kong NGOs Dominate List
Foreign NGOs had filed for a total of 130 temporary activities in the first six months of the year (we have only included those activities that had a start date on or before June 30, 2017). Sichuan (28), Guangdong (16), and Guizhou (13) saw the highest number of temporary activities. We classified these activities using the same 27 sectors that we applied to the foreign NGO representative offices. Again, each temporary activity could be classified as more than one sector.
Figure 5
The distribution of temporary activities’ sectors differed in some notable ways from those of registered offices. For example, while trade was the most prevalent field of work for foreign NGOs with representative offices in China, only two temporary activities were trade-related (see Figure 5). Likewise, there were 14 representative offices working on economic development, but no temporary activities in the same sector. Nevertheless, there were some broad similarities between the types of issues that representative offices and temporary activities were focused on. Health (14 activities, or 11 percent of all filed temporary activities), education (32, 25 percent), and poverty alleviation (23, 18 percent) were popular sectors for both temporary activities and representative offices. It is likely that the relative popularity of these sectors is reflective of more general Chinese government priorities; for example, a provincial Public Security Bureau is more likely to look favorably upon projects involving poverty alleviation, especially after the State Council’s recently announced five-year (2016-2020) plan targeted at poverty.
Figure 6
Figure 7
Hong Kong and the United States were once again the top two places of origin, but unlike the case of representative offices, more than 60 percent of the temporary activities were conducted by NGOs originating in Hong Kong (79 out of 130) (Figure 6). A large part of this figure came from a single organization, Oxfam Hong Kong, which alone conducted 33 of the temporary activities. Most (28) of Oxfam Hong Kong’s activities were filed on or before June 1, one day before it successfully registered its representative office in Guangdong on June 2; many organizations have reported holding temporary activities so that they can continue operating in China while waiting for their representative offices to be registered. Most of Oxfam’s activities were related to disaster relief and took place in Sichuan. In fact, all of the activities related to disaster relief (14) were carried out by only two foreign NGOs: Oxfam (12) and World Vision (2), both based out of Hong Kong. Even without taking into account Oxfam’s activities, Hong Kong was still the most common place of origin by far for organizations carrying out temporary activities.
Figure 8
As of June 30, no organizations had filed for activities related to LGBTQ or law and governance issues. Only one had filed for a media-related activity. These echo the low numbers of representative offices working in these fields. These numbers may be unsurprising given the chilling effect of historical and recent government censorship measures. Just last month (June), censors banned 84 categories of online video content, which included those promoting “unhealthy” views towards family and “abnormal sexual lifestyles” (such as homosexuality) and national disunity or ethnic discord. On the other hand, a closer look at the data on temporary activities may also offer some insight into how organizations are nevertheless finding ways to conduct work on more “sensitive” topics. For example, the U.S.-based F.Y. Chang Foundation and U.S.-China Education Trust have registered an activity under the neutral title of “Guest Lecture by Chinese-American Writer Helen Zia.” Zia is an award-winning journalist and activist who writes about gender, race, and LGBT issues, and the subject of the talk was Who Killed Vincent Chin?, a documentary film about race relations in the United States with themes of social justice and activism. We classified this activity under Education, since this was a lecture held by an education foundation at a university. Even though Helen Zia is also considered a social justice activist in the United States, she was described only as a “writer” in the activity title.
It remains to be seen if the trends observed in this analysis will continue to hold as more foreign NGOs register. Information on foreign NGO activity generally continues to be uneven and unreliable. Chinese government reports put the number of foreign NGOs at more than 7,000, though the origin of this figure is unknown, leaving observers with an uncertain baseline from which to judge the current number of successfully registered representative offices. Several groups have told The China NGO Project that they expect the rate of registration to pick up in the next few months—and a recent spate of registrations seems to confirm this rumor—but other groups remain stymied in their search to find a willing Professional Supervisory Unit. Six months in, with uncertainty lingering and authorities on the ground scrambling to implement an unfamiliar new law, foreign NGOs in China continue to wade into murky waters.
- We have decided not to remove seemingly “duplicate” organizations from our analysis, as, often, even offices from the same organization conduct very different activities, depending on their area of operations. For example, Hong Kong-based World Vision has registered six offices, each in a different province, and while the Yunnan office works on poverty alleviation, the Guangdong office does not but focuses on labor and migrants. Additionally, different representative offices are legally and functionally separate entities.↩
- This means that there is a total count of 304 sector-registrations across the 27 sectors despite there only being 144 offices.↩
- The majority of FNGOs we classified as trade were industry associations (e.g. the Malaysian Palm Oil Council), chambers of commerce (e.g. Russian Federation Chamber of Commerce and Industry), or other business-focused entities (e.g. U.S.-China Business Council).↩
