The Many “One Chinas”: Multiple Approaches to Taiwan and China

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The past year saw yet more heated debate over definitions of what “one China” means. Beijing asserts that there is widespread international acceptance of and agreement with its “one China principle,” which sees Taiwan as part of a Chinese state represented by the People’s Republic of China (PRC). The PRC accuses the United States of departing from what it claims is Washington’s long-standing acceptance of the PRC position, given U.S. efforts to improve cooperation and contact with Taipei. In reality, the United States’ “one China policy” states that Washington does not take a position on Taiwan’s sovereignty and merely “acknowledges” the existence of a Chinese position even as Washington officially recognizes the PRC as the government of China. The United States reserved the right to maintain unofficial relations with Taiwan as it sees fit. Taipei’s official position is that it is already independent as the Republic of China (Taiwan), whose jurisdiction covers Taiwan, Penghu, Kinmen, Matsu, and other outlying islands.

As the PRC becomes more insistent regarding its claims over Taiwan, Beijing is seeking to leave a clearer imprint of its preferences on the discourse over “one China.” PRC officials are increasingly couching other states’ positions in terms of its “one China” principle, at times claiming that originally stated differences are new deviations from or infractions on earlier understandings. By fostering an impression of broad agreement, Beijing’s claims establish a sense of legitimacy and a seeming moral high ground from where Beijing can highlight what it sees as inconsistencies or even betrayal by others. Given its greater ability and willingness to press its case, Beijing has encountered limited international resistance. For those interested in tracking developments in PRC policies and narratives, such evolving conditions mean greater importance in appreciating the range of stances states adopt toward PRC claims over Taiwan. They can provide a starting point from which to assess statements by predecessors or those of neighbors and partners, as well as any actual shifts in positions.

Countries around the world have used a broad range of official formulations beyond Beijing’s “one China principle,” Washington’s “one China policy,” and Taipei’s more ambiguous position. These widely varying positions largely originate from when the country in question established formal diplomatic relations with the PRC. Some had more reason to maintain separate and robust even if unofficial ties with Taiwan, while others saw little reason to weigh in on some far-flung dispute that they believed had little to do with them. Of course, a small number of states have maintained official ties with Taiwan as the Republic of China (ROC) rather than with PRC, adhering to Taipei’s approach during the authoritarian martial law period (1949–1987), when it claimed to be the legitimate government of all China. Taipei loosened this claim with the repeal of the 1948 “Temporary Provisions Effective During the Period of National Mobilization for Suppression of the Communist Rebellion” in 1991 and introduced additional articles to the ROC Constitution between 1991 and 2005 as part of efforts to enhance democracy, which also limited election activity to citizens of the “free area” of the ROC.

Principle, Policy, and Changing Circumstances

Given the centrality of language to the “one China” issue, official texts from the PRC, the United States, and Taiwan mark an important place to begin the discussion. Beijing’s “one China principle” contends that:

There is but one China in the world, Taiwan is an inalienable part of China’s territory, and the Government of the People’s Republic of China is the sole legal government representing the whole of China.

Surrounding the release of a 2022 white paper, “The Taiwan Question and China’s Reunification in the New Era,” by the PRC State Council’s Taiwan Affairs Office was a shift in emphasis but not meaning. As seen in this 2022 PRC Foreign Ministry statement, Beijing more frequently reiterates that its “one China principle”

has been clearly recognized by United Nations General Assembly Resolution 2758 of 1971. Since the founding of the People’s Republic of China in 1949, 181 countries have established diplomatic relations with China on the basis of the one-China principle. The one-China principle is a universal consensus of the international community and a basic norm in international relations.

Beijing tends to increasingly frame the United States’ “one China policy” within the context of the PRC’s own “one China principle” in its public statements. Such characterization of the U.S. position appears to be becoming more frequent. This perspective suggests that Beijing believes Washington’s position since the establishment of formal ties in 1979 agreed with the PRC line but now Washington is reneging on those past promises. The Mandarin language text of the 1978 Normalization Communiqué available on the PRC Foreign Ministry website states that the United States “recognizes” the PRC position on Taiwan. (The official website did not provide an English language text at the time of this article’s writing.)

The above claims diverge from the “one China policy” articulated by the United States as well as that of several other governments and entities. The text of UNGA Res 2758, for instance, makes no mention of Taiwan’s status, merely representation of China by the PRC rather than the “representatives of Chiang Kai-shek,” a point detailed by Jessica Drun and Bonnie S. Glaser. According to Washington, undergirding its “one China policy” are three U.S.-PRC joint communiqués, the Taiwan Relations Act (TRA), and the Six Assurances. This is a position that U.S. officials reiterated last year in light of public differences with Beijing.

More specifically, the 1979 U.S.-PRC Joint Communiqué announcing the establishment of official diplomatic ties states that the “Government of the United States of America acknowledges the Chinese position that there is one China and Taiwan is part of China.” The United States takes no official position on Taiwan’s sovereignty despite extending official diplomatic recognition to the PRC as the government of China. Similar to the 1972 Shanghai Communiqué, there is no U.S. recognition, endorsement, or support for the PRC view on Taiwan even if they choose not to challenge it. In fact, Washington and Beijing agreed to disagree at many points of the 1972 text. Further, when normalizing ties with the PRC, Washington undertook to “maintain cultural, commercial, and other unofficial relations with the people of Taiwan.”

Under the TRA, these sets of unofficial interactions include tracking the cross-strait military situation, enabling Taiwan to defend itself, and maintaining a military capability to intervene in a Taiwan contingency should U.S. policymakers decide to do so. A subsequent 1982 U.S.-PRC Joint Communiqué states a limiting and eventual drawdown of U.S. arm sales to Taiwan. However, Washington interpreted this arrangement as conditional on a decrease in the PRC threat to Taiwan. Washington concurrently issued Six Assurances to Taiwan, stating that the U.S. government:

• Has not agreed to set a date for ending arms sales to Taiwan
• Has not agreed to consult with the PRC on arms sales to Taiwan
• Will not play [a] mediation role between Taipei and Beijing
• Has not agreed to revise the Taiwan Relations Act
• Has not altered its position regarding the sovereignty over Taiwan . . .
• Will not exert pressure on Taiwan to enter into negotiations with the PRC

Beijing accepts neither the TRA nor the Six Assurances, indicating that the PRC sees the U.S. position they articulate as contravening the three joint communiqués.

Along with its transition away from authoritarian rule and toward democracy, Taiwan adjusted its position on “one China” to come to terms with changing realities. Under the Kuomintang’s (KMT) martial law, Taipei had maintained that it was the legitimate government of China, including the mainland and Taiwan. Facing growing diplomatic isolation, the 1970s and 1980s saw a shift in orientation from forcefully retaking the mainland to unification under Sun Yat-sen’s “Three People’s Principles.” Subsequent presidents floated “special state-to-state relations” and “one country on each side (of the Taiwan Strait)” as possibilities for cross-strait ties, only to be accused of “splittism” by Beijing. The PRC also rejected proposals for confederation floated by politicians in Taiwan. Administrations in Taipei sought to avoid formal declarations of independence, which they believed would trigger armed attack because Beijing considers it a red line. This despite the fact the PRC has never ruled Taiwan and the popular appeal of unification—especially speedy unification—is very low.

Taiwan’s population finds Beijing’s offer of a “one country, two systems” formula—as applied to Hong Kong, where Beijing’s control comes with promises of a “high degree of autonomy”—as unpersuasive, unappealing, and even untrustworthy. Wariness of the “one country, two systems” formula spiked following Beijing’s crackdown in Hong Kong and introduction of a National Security Law, which grants broad authority to regulate political activity. The current Democratic Progressive Party administration’s official position is that since Taiwan is already independent, a declaration of independence is unnecessary. Taipei rejects the language of the 1992 Consensus where the KMT claimed an understanding with the Chinese Communist Party (CCP) that allowed for “one China, different interpretations.”

Taipei does, however, accept the spirit of setting aside political differences for practical cooperation put forward during KMT-CCP meetings in 1992. Beijing has pressured Taipei to adopt the 1992 Consensus but concedes neither alternative formulations of “one China,” including “different interpretations,” nor Taipei’s call for practical collaboration. Polling indicates that Taiwanese people overwhelmingly prefer to maintain the current status quo and Taiwan’s ambiguous status but may become more sympathetic to independence should PRC threats dissipate. Such a position is unsurprising given broad popular acceptance that even a successful war of independence will be highly costly for Taiwan and restrains Taiwanese politicians from undertaking risky behavior. Whatever the views that Taiwanese people hold about Chinese culture, that does not seem to translate automatically into acceptance of PRC rule, abandonment of their current political system with its attendant rights and freedoms, or a provocative declaration of de jure independence.

The Other “One Chinas”

Apart from Beijing, Taipei, and Washington, other governments have a range of positions on “one China.” Most of these rest on how a given state assessed its relations with the PRC, the United States, and Taiwan when establishing formal ties with Beijing and as relations developed. Fourteen states maintain official relations with Taipei and formally recognize only the ROC. Since “one China” is generally not of primary importance to most states, many do not bother to adjust their stated positions even if practical circumstances evolve. As Beijing entices or cajoles more governments to recognize the PRC and as the formal diplomatic position of the ROC further declines, the case for the Taiwanese population to accept the ROC as representing their polity based on international legitimacy may diminish. Taiwanese people could well end up finding an alternative nomenclature for their government more appealing. This could inadvertently call Beijing’s attempts to convince people in Taiwan about the appeal of some idea of “one China” into further question.

In a 1996 essay, Lee Tzu-wen listed nine types of positions that states generally adopt on the “one China” issue at the point of establishing official diplomatic ties with Beijing. I list the categories in the table below, albeit with more precise language, and updated the names and numbers of states in each group as of January 2023. I also add a classification for states recognizing the ROC.

Based on the PRC’s Foreign Ministry website, Lee’s original data, and official documentation from other states, 51 countries now maintain positions on “one China” that substantively approach or replicate the PRC’s “one China principle” rather than the 181 countries that Beijing claims. In addition, the European Union recognizes the PRC as the sole legitimate government of China but maintains that it has and will develop relations and close cooperation with Taiwan on areas of common interest within this policy framework. In compiling the list, I included states whose “one China” position the PRC Foreign Ministry does not describe, such as Norway, Sweden, and Switzerland, but is available in official materials elsewhere. I excluded states whose “one China” stances could not be confirmed from official sources.

Note that numbers in each category will vary over time as more states recognize the PRC on one hand, and as various governments adjust language according to their shifting proximate concerns on the other. Practice may also differ from publicly stated positions. Despite not explicitly incorporating any statement about Taiwan in its “one China” statements, Norway officially counts Taiwanese nationals in the country as “Chinese” nationals. A 2022 House of Commons Foreign Affairs Committee report calls for the United Kingdom to stress that London acknowledges but does not accept the PRC “one China principle.” This was a stance the United Kingdom previously did not emphasize, especially when it sought a “golden age” of UK-PRC relations. London’s recalibration seems to come following renewed interest in Asia, rising PRC abrasiveness, and wariness about differences with Beijing even as the United Kingdom pursues economic exchange. Despite not mentioning Taiwan when establishing ties with the PRC in 1972, Germany’s foreign minister indicated recognition of Taiwan as part of China and opposed Taiwan's referendum on United Nations membership in an apparent bid to placate Beijing. The meaning of “China” in the German statement appears ambiguous, however.

The 1990 Singapore-PRC joint communiqué on establishing diplomatic ties made no mention of “one China” or Taiwan. A 2000 statement on bilateral cooperation recognized “one China” and that Taiwan is part of China alongside a separate sentence recognizing the PRC government. Then deputy prime minister Lee Hsien Loong stated opposition to Taiwan’s independence in 2004, after criticism by Beijing for his private trip to Taiwan. This point was also made by then prime minister Goh Chok Tong. Responding to PRC military exercises following then U.S. House of Representatives speaker Nancy Pelosi’s 2022 visit to Taiwan, Foreign Affairs Minister Vivian Balakrishnan indicated that Singapore, “is opposed to Taiwan independence and any unilateral moves to change the status quo” (emphasis added). Singapore maintains unofficial cooperation and exchanges with Taiwan like other states, some of which are extensive. They include unilateral military training in Taiwan.

States as well recognize each other’s mutual differences over “one China.” Following the large-scale PRC military exercises after Pelosi visited Taiwan, the Association of Southeast Asian Nations (ASEAN) issued a joint statement from members expressing concern for potential instability. The text was worded to “reiterate ASEAN member states’ support for their respective One-China” policies. This language appreciated the disparate stances on “one China” among ASEAN members that are neither reducible into each other nor necessarily Beijing’s “one China principle.” That the historical record reflects different and shifting stances on “one China” is unsurprising. Most international actors tend to view the issue as relatively unimportant, derivative of other considerations, and hence willing to state what is consistent with their interests at a given moment, if anything at all.

Contesting Concepts

As the PRC increasingly pursues claims over Taiwan as well as the South and East China Seas and seeks to establish greater control over key technologies and its own economy, Beijing will bring more of its resources and capabilities to bear in areas of consequence. These efforts include trying to impress and legitimate its claims, which is behavior common to major powers. Among areas of focus for Beijing will be trying to obtain widespread support for its “one China principle.” Bringing Taiwan under the PRC fold is, after all, an issue that the CCP—particularly its current leaders—identify as a central objective and key contemporary nationalism in the PRC. This means replacing separate and fully autonomous governance in Taiwan with PRC oversight. At a minimum, pushing in this direction may undermine Taipei’s global standing.

For other governments, lack of concern, urgency, and immediacy of Taiwan and PRC nationalist sentiments meant that they could previously use vague language about “one China” for gain and concessions. This was especially the case when Beijing was less persistent in trying to realize its claims. Contestation over Taiwan has intensified with increasing PRC assertiveness and growing U.S.-PRC competition. Domination over Taiwan—or the lack of thereof—can enable access or disrupt approaches to and communication links with South Korea and Japan as well force projection in the Western Pacific and Southeast Asia. Further elements that may factor into these governments’ stances on “one China” include: Taiwan’s central role in global semiconductor supply, promises of economic opportunity in the PRC, and differences between Taiwan’s liberal democracy and the PRC’s authoritarian system.

Contestation over the wording, interpretation, and application of “one China” positions is unlikely to abate—this despite its roots as a phrase that permitted governments to agree to disagree. The term has become tied to the CCP and PRC’s conceptions of self, including their domestic and international standing. These positions place in contention Taiwan’s political status, the will of its people, and the multiple ways Taiwan intersects with the different interests and concerns of other states and international actors. They include the U.S. and PRC strategic positions in Asia and beyond, as well as relations various states have with the two major powers and Taiwan. Growing differences over “one China” underscore the pressure mounting on once mutually convenient expediencies as the world evolves from the historical contexts of their inception. Awareness and understanding of the nuances and implications associated with various permutations of “one China” may be more crucial than ever before.

Corrections: The piece originally dated constitution changes limiting elections to citizens of the “free area” of the ROC to 2005. It has been amended to reflect changes that were introduced between 1991 and 2005. In addition, two sentences have been added reflecting Germany’s stance as of 2008.