Takashi Okamoto

China’s “Territorial Sovereignty” and Its Origins*
Takashi Okamoto**

Abstract
The roots of the Chinese concept of “territorial sovereignty” can be traced back to theconcepts for tributaries or dependencies: shudi and fanbu. Moreover, these concepts canalso be replaced by the word fanshu. Since the word fanshu was also used for lost shuguo,
such as Korea, Vietnam, and Ryukyu, the fear of losing territory came to be embedded inthe Chinese psyche from early on. Territory is a concept that implies sovereignty. This isin line with conventional theory. However, the notion that territorial sovereignty is always
at risk of being lost, must always be protected, and must never be yielded comes across as
a very Chinese way of thinking. The historical process by which territory was lost can besaid to have been imprinted in the Chinese understanding of the legal concept of “territorialsovereignty.” Since this is the starting point of some of the demands and claims of modern
China, we might suspect that the roots of certain ongoing disputes can also be traced to thishistorical background.

Paul Reichler, the lead counsel for the Philippines in its arbitration case with Beijing overclaims in the South China Sea, has said it should be possible to have a dialogue withChina using a common language and the language of law. Put differently, this means that
we are currently not speaking the same language and that we are not having a dialogue
with China. While what China says and what the West and Japan say might appear to be the sameon the surface, their messages have entirely different content.
My mission as a historian specializing in China is to look to the past and analyze why andwhere this situation came about. I will focus on the notion of “territorial sovereignty” as a typicalexample of terms and concepts that have different meanings, depending on the user. The term
“territorial sovereignty” gained currency in China no more than about a century ago. The concept
did not exist prior to that, and it may not have been required by the order of things. I would liketo start by discussing this background.

1. The Qing’s World Order and the Fanshu Concept

What was Chinaʼs world order prior to the 20th century? I have tried to give an explanation byway of an illustration. There is no limit to how much detail I can get into about the Qingʼs worldorder, so I will break it down into four broad categories.

*This article is based on a presentation made by the author at the symposium “Territory and Maritime
Issues in East Asia and their Origins” held by JIIA, Doshisha University Center for Study of South China
Sea and Faculty of Law Doshisha University on March 2, 2019.

** Takashi Okamoto is Professor at Kyoto Prefectural University.

13Japan Review Vol.3 No.2 Fall 2019

What was China’s world order prior to the 20th century? I have tried to give anby wayandof Its
anOrigins
illustration. There is no limit to how much detail I can get into
China’sexplanation“Territorial Sovereignty”
about the Qing’s world order, so I will break it down into four broad categories.

hushi (互市): linked by trade
E.g.: Western powers, Japanshuguo (屬國): tributaries
E.g.：Korea, Ryukyu, Vietnam

fanbu (藩部)
E.g.：Tibet, Mongolia, Xinjiangzhi- sheng (直省): provinces
China proper

Fig. 1 Four Categories in the Qing’s World Order
Fig. 1 Four Categories in the Qing’s World OrderFirst, we have countries linked by trade relations, or hushi, represented by the green
early 19C
late 19C – 20C
arrows in Fig. 1. The areas marked with solid lines were tributaries, meaning countries
Korea
Korea
taking part in tributary
relations,and were referred to as shuguo in the Chinese
RyukyuRyukyuterminology of thattime. These were countries such as Korea, Ryukyu, and Vietnam.
Holland
Then there wereVietnamthe fanbu, areasVietnam
in the northwest indicated with broken lines. TheTributarySiam
Siamshuguo ( 屬國 )was so-called“Loss”
fanbu wereTibet,Mongolia, and present-day Xinjiang. Finally, there
Chinachaogong( 朝貢)Portugal
proper, in the southeast of the map, which was where the Han Chinese lived. The term
Sulu
Sulu
for this area wasBurmazhi-sheng.
Burma
The Qing’s relationships
can beLaos
classified in four categories based on original sources
LaosXinjiang
Xinjiangfrom that time, andbe summarizedin Table 1. And Fig. 1. is the map on which theTerritory
shudi ( 屬地 )
Tibet
Tibet
relationships
lingtu ( 領土 )fanbu( 藩部 ) have been diagrammed.
Mongolia
Mongolia
Western countries and Japan had hushi relationships with the Qing. This means that
RussiaRussiathere were no formal relationsPortugal
between governments, just local trade. Theserelationships generally
treaty-based ties, beginning in the second half ofFrance changed intoFrance
TreatyDiplomacy
GreatGreattheTradenineteenth century.
These countries
entered into Relations
diplomatic relationships
withhushi ( 互市 )Britain
Britain
China at a relatively early stage.
HollandJapanJapan
2
1

Table 1 Transformation of the Qing’s World Order Except China Proper

1

Table prepared by the author based on Okamoto Takashi, Chugoku no tanjo [The Birth of China](University of Nagoya Press, 2017), p. 413, Table 5.

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Japan Review Vol.3 No.2 Fall 2019

Takashi Okamoto

First, we have countries linked by trade relations, or hushi, represented by the green arrows
in Fig. 1. The areas marked with light blue lines were tributaries, meaning countries taking partin tributary relations, and were referred to as shuguo in the Chinese terminology of that time.
These were countries such as Korea, Ryukyu, and Vietnam. Then there were the fanbu, areasin the northwest indicated with blue lines. The fanbu were Tibet, Mongolia, and present-day
Xinjiang. Finally, there was so-called China proper, in the southeast of the map, which was wherethe Han Chinese lived. The term for this area was zhi-sheng.
The Qingʼs relationships can be classified in four categories based on original sources fromthat time, and be summarized in Table 1. And Fig. 1 is the map on which the relationships havebeen diagrammed.
Western countries and Japan had hushi relationships with the Qing. This means that there
were no formal relations between governments, just local trade. These relationships generally
changed into treaty-based ties, beginning in the second half of the nineteenth century. Thesecountries entered into diplomatic relationships with China at a relatively early stage.
What can we say about the other categories of shuguo and fanbu, which are marked in blue on
the map? This question has to do with the concept of “territorial sovereignty.”
First, we have the expression shuguo. Shuguo refers to countries surrounding China that gave
tribute to the Qing. We talk about shuguo (tributary) and shangguo (superior country) because
when countries offer tribute to the Chinese emperor, this creates a hierarchical relationship ofsovereign and subject. Since tribute and the sovereign-subject hierarchy were based on Confucianconcepts and rituals, such relations were formed with neighbors that understood the Chinese
language and Confucianism.
Conversely, other countries could not enter into shuguo or tributar y relations. While acountry such as Japan ended up in the hushi category rather than shuguo because of historicalcircumstances, it would not be an exaggeration to say that ultimately this was because Japan did
not understand Chinese and Confucianism.
Likewise, fanbu was another categor y where Chinese and Confucianism did not apply.
Fanbu specifically referred to Mongolia, Tibet, and Xinjiang. They were similar in that theygeographically belonged to an inland world of steppes, did not use Chinese as their language, anddid not follow Confucianism. Xinjiang was Muslim and Turkic, while Mongolia and Tibet adheredto Tibetan Buddhism. They differed quite markedly from the countries in the other categories interms of social organization, manners, and customs.
This is why I differentiate between shuguo and fanbu here. Yet, looking at Chinese sourcesfrom the time, the two are often jointly referred to as fanshu, which is a relatively uncommon
Chinese word.

2. From Fanbu to Shudi

Map 1 on Fig. 2 shows the situation on the Korean peninsula following the First Sino-JapaneseWar. After this conflict, as was stipulated in the first article of the Treaty of Shimonoseki, Korea
became “independent” as the Great Korean Empire. That is, Korea ceased to be a Chinese shuguo.
Many sources at that time described Koreaʼs “independence” as the termination of Koreaʼs status
as a Chinese shuguo and fanshu.

15Japan Review Vol.3 No.2 Fall 2019

Japanese War. After this conflict, as was stipulated in the first article of the Treaty ofShimonoseki, Korea became “independent” as the Great Korean Empire. That is, Korea
ceased to be a Chinese shuguo. Many sources at that time described Korea’s
China’s “Territorial Sovereignty” and Its Origins“independence” as the termination of Korea’s status as a Chinese shuguo and fanshu.

Map 1
Da Qing niansan sheng yudi
quantu [Complete map of the 23
provinces of the Great Qing ]

Map 2

Map 3

2Fig. Fig.
2 “Loss”(Dependencies)
Riseof “Sovereignty”
2Shuguo (Dependencies)
and and
Rise of“Sovereignty”
2 “Loss”ofofShuguo

Meanwhile, sources of the time commonly treated shuguo and fanbu as being more or lessshuguoand fanbu
as being
sources ofterms.
the timecommonlytreatedequalMeanwhile,and interchangeable
Even
though theKorean
peninsulaand Tibet
weremoregoverned
completely differently, they were frequently referred to using the same terms and Chinese words.
2 (MapRetrieved
from the Libraryof Congress;(Map2) Adapted
fromNot
only 1)was
Korea sometimes
called fanshu
like Tibet
andMongolia,
but “Guafen”
Tibet andmap
Mongolia
inOkamotoTakashi,
Zoho:
Chugoku“Han-Nichi”
noGenryu[Enlargededition:
Thewere also called shuguo by some sources.
originsof anti-Japanesein all
China] (ChikumaGakugei2019),
247;end of theVietnam,
Ryukyu, andsentiment
Korea hadceased
being shuguo
of Bunko,
the Qingby theXinmin
congbao[Renewingthepeople],no.
1(1902):
cover.
(Map3)
nineteenth centur y. It goes without saying that this was because they were annexed by theWestern powers and Japan. This is why the word
4 “loss” has been used in Table 1. The loss of theshuguo became a major issue.
In 1897, Korea became the last shuguo to lose its ties with the Qing. At around the sametime, the Western powers began to obtain rights in China in a process called “the scramble forconcessions,” which lasted until the end of the nineteenth century. The Chinese at the time called
this process guafen, meaning a melon being taken apart and eaten, which is illustrated in Fig. 2–
Map 2. Qing and Chinese officials of this time and beyond became extremely worried about thepotential partitioning of China.
The Qing became obsessed with the idea that while the shuguo were lost, they had to retain
the remaining fanbu or they would have a real crisis on their hands.
Even before this, from the 1880s into the 1890s, Tibet, Mongolia, and Xinjiang―which had
been referred to as fanbu―increasingly came to be referred to as “colonies,” especially by lateQing era Chinese diplomats stationed in the West, as well as by Han Chinese who had absorbed
Western scholarship and concepts.
This identification of fanbu as colonies seems to have started with the translation of Westernterms, such as “colony” and “colonial office,” into Chinese. The opposite, of Chinese terms being
used for Western concepts, also started to happen, so fanbu finally came to be seen as dependent
as colonies, regardless of the actual facts. These dependencies or colonies came to be called shudi
in contemporary Chinese.
Yet looking at the word shudi, the Chinese characters representing this word are similar tothe previously mentioned shuguo. The characters and meaning also have things in common with2(Map 1) Retrieved from the Library of Congress; (Map 2) Adapted from “Guafen” map in OkamotoTakashi, Zoho: Chugoku “Han-Nichi” no Genryu [Enlarged edition: The origins of anti-Japanesesentiment in China] (Chikuma Gakugei Bunko, 2019), p. 247; (Map 3) Xinmin congbao [Renewing thepeople], no. 1 (1902): cover.

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Japan Review Vol.3 No.2 Fall 2019

Takashi Okamotofanshu, so when seen from the perspective of other countries, such as the Western powers andJapan, it appeared as if the shudi were no different from shuguo, and that the areas remained
the same as before. In fact, the English translation for all of these words were the same:“dependencies.”

3. “Territorial Sovereignty”

During the final years of the nineteenth century and into the twentieth century, China ʼs senseof crisis with regard to the countryʼs partitioning by the Western powers reached its climax.
Especially in the early twentieth century, the areas that were fanbu were caught between Russia
in the north and British India in the south. The fanbu became a site of competition among theimperialist powers in the so-called Great Game. The Chinese devoted greater efforts to keepthese areas inside China and prevent the fanbu from being taken by other countries.
We should pay special attention to 1905. Even before that year, calls for China to become ahomogenous nation-state and to be unified, as if all of the Qingʼs territory was homogeneousand painted in one color, as shown in Map 3, had become extremely frequent among the HanChinese. We might perhaps call this the start of nationalism. This was the result of going throughthe process depicted in Maps 1 to 3 of Fig. 2, during the decade after the Treaty of Shimonoseki
in 1895.
At a time when such nationalism was growing, how could Tibet, Mongolia, and Xinjiang,called shudi or fanbu, be defined? It was then that the concept of “sovereignty” first appeared in
Chinese political discourse. Other countries had previously used the term “suzerainty” in place of“sovereignty.”
Suzerainty is an unclear and ambiguous concept, but it was likely its ambiguity that gave it
its versatility. All of the Qingʼs shudi, shuguo, and fanbu were given the same English designationof “dependency.” The meaning was simply that these areas were dependent, regardless of theactual facts, and this dependency was coupled with the concept of suzerainty. It must have been aconvenient term for indicating a hierarchical relationship without having to consider the facts ofthe matter.
Yet at this late hour, leaving Tibet and Mongolia as they were risked having them suffer thesame fate as the shuguo―Ryukyu, Vietnam, Burma, and Korea―which had also been perceived
as dependencies. Han Chinese elites and officials came to fear not only the separation of theseareas from China and their loss, but also that this might trigger the guafen of China proper.
Suzerainty became insufficient as a safeguard, so the Chinese started invoking the concept ofsovereignty instead.
If so, fanbu, fanshu, and shudi also became unusable terms since they were coupled withthe concept of suzerainty. The Chinese needed a new lexical concept that could be paired withsovereignty and could replace shudi, but what could it be?
The answer was lingtu, the Chinese translation of “territory.” The word “territory” in Chinese
was likely a legal concept that was formulated based on the Japanese ryochi, but the concept
started to be used in China as well. The emergence of the concept of sovereignty neatly coincidedwith the rise of nationalism in China.
The concept of territory became widely known and established in 1911–1912, that is, during
the 1911 Revolution, when the Qing Dynasty gave way to the Republic of China. The Provisional
Constitution of the Republic of China states, “The territory of the Republic of China shall consistof twenty-two xing-sheng [provinces], Inner Mongolia, Outer Mongolia, Tibet, and Qinghai,”
explicitly using the word “territory” and defining its extent. As part of this political transition, theconcepts of “territory” and “sovereignty” in China came to be established with meanings similar
to their modern-day usages.

17Japan Review Vol.3 No.2 Fall 2019

Republic of China shall consist of twenty-two xing-sheng [provinces], Inner Mongolia,
Outer Mongolia, Tibet, and Qinghai,” explicitly using the word “territory” and defining
its extent. As part of this political transition, the concepts of “territory” and “sovereignty”

China’s “Territorial Sovereignty” and Its Origins

in China came to be established with meanings similar to their modern-day usages.

more dependence

Sovereignty

Shudi
Fanbu
th

18 C.

lingtu(territory)(colony)

Fanth

Shu

20 C.

Shuguo (vassal）
Fanshu（dependency）
less dependence

loss
Suzerainty

33Fig. Fig.
3 Concepty”:from
from
Fanshu/Shudi
to Lingtu
Fanshu/Shudi
to Lingtu
3 Conceptofof“Territor“Territory”:

Conclusion: The Origins and Development of “Territorial Sovereignty”

Conclusion: The Origins and Development of “Territorial Sovereignty”
The roots of the Chinese concept of “territorial sovereignty” can be traced back to the concepts
The rootsor
ofdependencies:
the Chinese conceptof “territorialsovereignty”
be tracedto thefor tributaries
shudi andfanbu. Moreover,these canconcepts
can back
also bereplaced
byconcepts
the wordfor
fanshu.
Since theword fanshu wasalsoandused
for lost
shuguo, such
Korea, Vietnam,
tributaries
or dependencies:
shudi
fanbu
. Moreover,theseasconcepts
canand Ryukyu, the fear of losing territory came to be embedded in the Chinese psyche from early
also be replaced by the word fanshu. Since the word fanshu was also used for lost shuguo,
on.
suchas Korea,
and implies
Ryukyu,sovereignty.
the fear of losing
territory
to be embedded
Territory is a Vietnam,
concept that
This isin line camewith conventional
theor y.
However,the notion
thatfrom
territorial
sovereignty is always at risk of being lost, must always bein the Chinese
psycheearly on.
protected,andmust
never
beyielded
comes
across asa very
wayof thinking.theory.
Territory is a concept that implies
sovereignty.
Thisis inChineseline withconventional
The concept of “territory” in Chinese language started out as a designation specifically forHowever, the notion that territorial sovereignty is always at risk of being lost, must
Tibet and Mongolia, but it then became a concept applicable to other places because they werealways fanbu
be protected,and must never be yielded comes across as a very Chinese way oforiginallyand fanshu.
thinking.
The concept of “territory” in Chinese language started out as a designation specificallyfor Tibet and Mongolia, but it then became a concept applicable to other places because
they were originally fanbu and fanshu.

3Chart prepared by the author based on Okamoto, Chugoku no tanjo, 424, Figure 7.
7

3Chart prepared by the author based on Okamoto, Chugoku no tanjo, p. 424, Figure 7.

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Japan Review Vol.3 No.2 Fall 2019

Takashi OkamotoFig. 4 Chinese Nation in the Republican Era4Fig. 4 is a map used in China during the Republican period. Chinaʼs territory at the time isindicated in orange. There were nonetheless some maps in circulation that showed, inside adotted line, lost territory that had to be recovered.
The historical process by which territory was lost can be said to have been imprinted in theChinese understanding of the legal concept of “territorial sovereignty.” Since this is the starting
point of some of the demands and claims of modern China, we might suspect that the roots ofcertain ongoing disputes can also be traced to this historical background.

4

Prepared by the author based on “Zhonghua guochi tu” [Map of Chinese national humiliation], Zuixin
Zhongguo ditu [Most recent maps of China] (Dongfang yudi xueshe, 1938).

19Japan Review Vol.3 No.2 Fall 2019