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"One country, two systems" is a constitutional principle of the People's Republic of China (PRC) describing the governance of the
special administrative regions The special administrative regions (SAR) of the People's Republic of China are one of the provincial-level administrative divisions of the People's Republic of China directly under the control of its Central People's Government (State Co ...
of
Hong Kong Hong Kong ( (US) or (UK); , ), officially the Hong Kong Special Administrative Region of the People's Republic of China (abbr. Hong Kong SAR or HKSAR), is a city and special administrative region of China on the eastern Pearl River Delta i ...
and
Macau Macau or Macao (; ; ; ), officially the Macao Special Administrative Region of the People's Republic of China (MSAR), is a city and special administrative region of China in the western Pearl River Delta by the South China Sea. With a pop ...
. The constitutional principle was formulated in the early 1980s during negotiations over Hong Kong between China and the
United Kingdom The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom (UK) or Britain, is a country in Europe, off the north-western coast of the European mainland, continental mainland. It comprises England, Scotlan ...
. It provided that there would be only
one China The term One China may refer to one of the following: * The One China principle is the position held by the People's Republic of China (PRC) that there is only one sovereign state under the name China, with the PRC serving as the sole legit ...
, but that these regions could retain their own economic and administrative systems, while the rest of
Mainland China "Mainland China" is a geopolitical term defined as the territory governed by the People's Republic of China (including islands like Hainan or Chongming), excluding dependent territories of the PRC, and other territories within Greater Chin ...
uses the
socialism with Chinese characteristics Socialism with Chinese characteristics ( zh, s=中国特色社会主义, hp=Zhōngguó tèsè shèhuìzhǔyì) is a set of political theories and policies of the Chinese Communist Party (CCP) that are seen by their proponents as representing M ...
system. Under the principle, each of the two regions could continue to have its own governmental system, legal, economic and financial affairs, including trade relations with foreign countries, all of which are independent from those of the Mainland. The PRC has also proposed to apply the principle in the unification it aims for with
Taiwan Taiwan, officially the Republic of China (ROC), is a country in East Asia, at the junction of the East and South China Seas in the northwestern Pacific Ocean, with the People's Republic of China (PRC) to the northwest, Japan to the northe ...
. However, since 2020, as a result of the passage of the National Security Law by Hong Kong on 30 June of the same year, the
United States The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country primarily located in North America. It consists of 50 U.S. state, states, a Washington, D.C., federal district, five ma ...
and United Kingdom condemned the Chinese government of seriously breaching the principle.


Background


In the context of Hong Kong

Hong Kong was a
colony In modern parlance, a colony is a territory subject to a form of foreign rule. Though dominated by the foreign colonizers, colonies remain separate from the administration of the original country of the colonizers, the ''metropole, metropolit ...
of the United Kingdom, ruled by a
governor A governor is an administrative leader and head of a polity or political region, ranking under the head of state and in some cases, such as governors-general, as the head of state's official representative. Depending on the type of political ...
appointed by the monarch of the United Kingdom, for 156 years from 1841 (except for four years of Japanese occupation during
WWII World War II or the Second World War, often abbreviated as WWII or WW2, was a world war that lasted from 1939 to 1945. It involved the World War II by country, vast majority of the world's countries—including all of the great power ...
) until 1997, when it was reverted to Chinese sovereignty. China agreed to accept some conditions, as is stipulated in the
Sino-British Joint Declaration The Sino-British Joint Declaration is a treaty between the governments of the United Kingdom and China signed in 1984 setting the conditions in which Hong Kong was transferred to Chinese control and for the governance of the territory after ...
, such as the drafting and adoption of Hong Kong's "mini-constitution" Basic Law before its return. The Hong Kong Basic Law ensured that Hong Kong will retain its
capitalist Capitalism is an economic system based on the private ownership of the means of production and their operation for profit. Central characteristics of capitalism include capital accumulation, competitive markets, price system, pri ...
economic system and own currency (the
Hong Kong Dollar The Hong Kong dollar (, sign: HK$; code: HKD) is the official currency of the Hong Kong Special Administrative Region. It is subdivided into 100 cents or 1000 mils. The Hong Kong Monetary Authority is the monetary authority of Hong Kon ...
),
legal system The contemporary national legal systems are generally based on one of four basic systems: civil law, common law, statutory law, religious law or combinations of these. However, the legal system of each country is shaped by its unique history an ...
,
legislative system Law is a set of rules that are created and are enforceable An unenforceable contract or transaction is one that is valid but one the court will not enforce. Unenforceable is usually used in contradiction to void (or ''void ab initio'') a ...
, and same human rights and freedoms, as a special administrative region (SAR) of China for 50 years. Set to expire in 2047, the current arrangement has permitted Hong Kong to function as its own entity under the name "Hong Kong, China" in many international settings (e.g. the
WTO The World Trade Organization (WTO) is an intergovernmental organization that regulates and facilitates international trade. With effective cooperation in the United Nations System, governments use the organization to establish, revise, and e ...
and the Olympics)."1898 and all that—a Brief History of Hong Kong." ''The Economist'', 28 June 1997 The Chinese renminbi is not legal tender in Hong Kong. Likewise, the Hong Kong dollar is not accepted in stores in mainland China. With this arrangement, a permit or special visa () is required when passing between the borders of Hong Kong and mainland China, and people in Hong Kong hold Hong Kong SAR passports rather than
Chinese passport The People's Republic of China Passport (), commonly referred to as the Chinese passport, is a passport issued to citizens of the People's Republic of China (PRC) for the purpose of international travel, and entitles its bearer to the protecti ...
s. The
official languages An official language is a language given supreme status in a particular country, state, or other jurisdiction. Typically the term "official language" does not refer to the language used by a people or country, but by its government (e.g. judiciary, ...
are a major factor besides the history of the former colony that has made Hong Kong and mainland China distinct from each other, as
Cantonese Cantonese ( zh, t=廣東話, s=广东话, first=t, cy=Gwóngdūng wá) is a language within the Chinese (Sinitic) branch of the Sino-Tibetan languages originating from the city of Guangzhou (historically known as Canton) and its surrounding ar ...
and
English English usually refers to: * English language * English people English may also refer to: Peoples, culture, and language * ''English'', an adjective for something of, from, or related to England ** English national id ...
are the most widely used languages in Hong Kong, while
Mandarin Mandarin or The Mandarin may refer to: Language * Mandarin Chinese, branch of Chinese originally spoken in northern parts of the country ** Standard Chinese or Modern Standard Mandarin, the official language of China ** Taiwanese Mandarin, Stand ...
is the official language of mainland China. The central government in Beijing maintains control over Hong Kong's foreign affairs as well as the legal interpretation of the Basic Law. The latter has led democracy advocates and some Hong Kong residents to argue that the territory has yet to achieve
universal suffrage Universal suffrage (also called universal franchise, general suffrage, and common suffrage of the common man) gives the right to vote to all adult citizens, regardless of wealth, income, gender, social status, race, ethnicity, or political sta ...
as promised by the Basic Law, leading to mass demonstrations in 2014.


In the context of Macau

A
colony of Portugal The Portuguese Empire ( pt, Império Português), also known as the Portuguese Overseas (''Ultramar Português'') or the Portuguese Colonial Empire (''Império Colonial Português''), was composed of the overseas colonies, factories, and the l ...
for 442 years from 1557,
Macau Macau or Macao (; ; ; ), officially the Macao Special Administrative Region of the People's Republic of China (MSAR), is a city and special administrative region of China in the western Pearl River Delta by the South China Sea. With a pop ...
was returned to Chinese sovereignty in 1999. In the
Joint Declaration on the Question of Macau The Joint Declaration on the Question of Macau, or Sino-Portuguese Joint Declaration, was a treaty between Portugal and the People's Republic of China over the status of Macau. The full name of the treaty is Joint Declaration of the Government of ...
, the drafting and adoption of Macau's mini-constitution before its return was foreseen. Like Hong Kong, a basic law would ensure that Macau retained its economic system, currency (the pataca),
legal system The contemporary national legal systems are generally based on one of four basic systems: civil law, common law, statutory law, religious law or combinations of these. However, the legal system of each country is shaped by its unique history an ...
(which is based on Portuguese civil law),
legislative system Law is a set of rules that are created and are enforceable An unenforceable contract or transaction is one that is valid but one the court will not enforce. Unenforceable is usually used in contradiction to void (or ''void ab initio'') a ...
, and people's rights and freedom for 50 years, as a special administrative region (SAR) of China. Set to expire in 2049, the agreement has permitted Macau to function as its own entity in many international settings (e.g.
WTO The World Trade Organization (WTO) is an intergovernmental organization that regulates and facilitates international trade. With effective cooperation in the United Nations System, governments use the organization to establish, revise, and e ...
and the Olympics) rather than as a part of China. As Macau has its own currency, the Chinese renminbi is not legal tender in Macau; the pataca is not even accepted in stores in China. With this agreement, a permit or visa is required when crossing between the borders of Macau and China, and people in Macau generally hold Macau SAR passports rather than mainland Chinese passports. Like Hong Kong, the
official languages An official language is a language given supreme status in a particular country, state, or other jurisdiction. Typically the term "official language" does not refer to the language used by a people or country, but by its government (e.g. judiciary, ...
are a major factor that has made Macau and China distinct from each other besides the history of the former colony, as Cantonese and
Portuguese Portuguese may refer to: * anything of, from, or related to the country and nation of Portugal ** Portuguese cuisine, traditional foods ** Portuguese language, a Romance language *** Portuguese dialects, variants of the Portuguese language ** Port ...
are the official languages in Macau, while Mandarin is the official language of China. The central government in Beijing also maintains control over Macau's foreign affairs as well as the legal interpretation of the Basic Law.


In the context of Taiwan

The first noted mention of "one country, two systems" as a concept is believed to be a proposal from
Deng Xiaoping Deng Xiaoping (22 August 1904 – 19 February 1997) was a Chinese revolutionary leader, military commander and statesman who served as the paramount leader of the China, People's Republic of China (PRC) from December 1978 to November 1989. Aft ...
to promote
Chinese unification Chinese unification, also known as the Cross-Strait unification or Chinese reunification, is the potential unification of territories currently controlled, or claimed, by the People's Republic of China ("China" or "Mainland China") and the ...
over the separated territories held by the
Kuomintang The Kuomintang (KMT), also referred to as the Guomindang (GMD), the Nationalist Party of China (NPC) or the Chinese Nationalist Party (CNP), is a major political party in the Republic of China, initially on the Chinese mainland and in Tai ...
-led Nationalist government of the
Republic of China Taiwan, officially the Republic of China (ROC), is a country in East Asia, at the junction of the East and South China Seas in the northwestern Pacific Ocean, with the People's Republic of China (PRC) to the northwest, Japan to the northea ...
across the Taiwan Strait. In 1987, the president of the Republic of China at the time,
Chiang Ching-kuo Chiang Ching-kuo (27 April 1910 – 13 January 1988) was a politician of the Republic of China after its Retreat of the Republic of China to Taiwan, retreat to Taiwan. The eldest and only biological son of former president Chiang Kai-she ...
, counter-proposed with the alternative of "".


Application to Hong Kong and Macau

Chinese
paramount leader Paramount leader () is an informal term for the most important political figure in the People's Republic of China (PRC). The paramount leader typically controls the Chinese Communist Party (CCP) and the People's Liberation Army (PLA), often hol ...
Deng Xiaoping Deng Xiaoping (22 August 1904 – 19 February 1997) was a Chinese revolutionary leader, military commander and statesman who served as the paramount leader of the China, People's Republic of China (PRC) from December 1978 to November 1989. Aft ...
proposed the principle during negotiation with British
prime minister A prime minister, premier or chief of cabinet is the head of the cabinet and the leader of the ministers in the executive branch of government, often in a parliamentary or semi-presidential system. Under those systems, a prime minister is ...
Margaret Thatcher Margaret Hilda Thatcher, Baroness Thatcher (; 13 October 19258 April 2013) was Prime Minister of the United Kingdom from 1979 to 1990 and Leader of the Conservative Party from 1975 to 1990. She was the first female British prime ...
over the expiration of the United Kingdom's lease on the
New Territories The New Territories is one of the three main regions of Hong Kong, alongside Hong Kong Island and the Kowloon Peninsula. It makes up 86.2% of Hong Kong's territory, and contains around half of the population of Hong Kong. Historically, it ...
(including
New Kowloon New Kowloon is an area in Hong Kong, bounded in the south by Boundary Street, and in the north by the ranges of the Eagle's Nest, Beacon Hill, Lion Rock, Tate's Cairn and Kowloon Peak. It covers the present-day Kwun Tong District and Wong Tai ...
) of Hong Kong in 1997. The same principle was proposed in talks with
Portugal Portugal, officially the Portuguese Republic, In recognized minority languages of Portugal: :* mwl, República Pertuesa is a country located on the Iberian Peninsula, in Southwestern Europe, and whose territory also includes the Macaronesian ...
about Macau. The principle is that, upon reunification, despite the practice of socialism in mainland China, both Hong Kong and Macau, which were colonies of the United Kingdom and Portugal respectively, could retain their established system under a high degree of autonomy for up to 50 years after reunification. However, what would happen after 2047 and 2049 for Hong Kong and Macau respectively has never been publicly stated. Chapter 1, Article 5 of the
Hong Kong Basic Law The Basic Law of the Hong Kong Special Administrative Region of the People's Republic of China is a national law of China that serves as the organic law for the Hong Kong Special Administrative Region (HKSAR). Comprising nine chapters, 160 a ...
, the constitutional document of the Hong Kong Special Administrative Region, reads: The establishment of these regions, called "special administrative regions" (SARs), is authorised by Article 31 of the
Constitution of the People's Republic of China The Constitution of the People's Republic of China is the supreme law of the People's Republic of China. It was adopted by the 5th National People's Congress on December 4, 1982, with further revisions about every five years. It is the fou ...
, which states that the state may establish SARs when necessary, and that the systems to be instituted in them shall be prescribed by law enacted by the
National People's Congress The National People's Congress of the People's Republic of China (NPC; ), or simply the National People's Congress, is constitutionally the supreme state authority and the national legislature of the People's Republic of China. With 2,9 ...
in light of the specific conditions. The SARs of Hong Kong and Macau were formally established on 1 July 1997 and 20 December 1999 respectively, immediately after the People's Republic of China (PRC) assumed sovereignty over these respective regions.


Framework

The two SARs of Hong Kong and Macau are responsible for their domestic affairs including, but not limited to, the
judiciary The judiciary (also known as the judicial system, judicature, judicial branch, judiciative branch, and court or judiciary system) is the system of courts that adjudicates legal disputes/disagreements and interprets, defends, and applies the law ...
and courts of final appeal (last resort), immigration and customs,
public finance Public finance is the study of the role of the government in the economy. It is the branch of economics that assesses the government revenue and government expenditure of the public authorities and the adjustment of one or the other to achi ...
,
currencies A currency, "in circulation", from la, currens, -entis, literally meaning "running" or "traversing" is a standardization of money in any form, in use or circulation as a medium of exchange, for example banknotes and coins. A more general defi ...
and
extradition Extradition is an action wherein one jurisdiction delivers a person accused or convicted of committing a crime in another jurisdiction, over to the other's law enforcement. It is a cooperative law enforcement procedure between the two jurisd ...
. The SARs are also exempt from mainland laws mandating the use of
simplified characters Simplified Chinese characters are standardized Chinese characters used in mainland China, Malaysia and Singapore, as prescribed by the '' Table of General Standard Chinese Characters''. Along with traditional Chinese characters, they are one ...
in publishing and
Mandarin Mandarin or The Mandarin may refer to: Language * Mandarin Chinese, branch of Chinese originally spoken in northern parts of the country ** Standard Chinese or Modern Standard Mandarin, the official language of China ** Taiwanese Mandarin, Stand ...
in public education and most broadcasting. The
diplomatic relations Diplomacy comprises spoken or written communication by representatives of states (such as leaders and diplomats) intended to influence events in the international system.Ronald Peter Barston, ''Modern diplomacy'', Pearson Education, 2006, p. 1 ...
and
military defence A military, also known collectively as armed forces, is a heavily armed, highly organized force primarily intended for warfare. It is typically authorized and maintained by a sovereign state, with its members identifiable by their distin ...
of the two SARs however, is the responsibility of the
Central People's Government The State Council, constitutionally synonymous with the Central People's Government since 1954 (particularly in relation to local governments), is the chief administrative authority of the People's Republic of China. It is chaired by the pr ...
in Beijing. Hong Kong continues using
English common law English law is the common law legal system of England and Wales, comprising mainly criminal law and civil law, each branch having its own courts and procedures. Principal elements of English law Although the common law has, historically, bee ...
while Macau continues using the
Portuguese Portuguese may refer to: * anything of, from, or related to the country and nation of Portugal ** Portuguese cuisine, traditional foods ** Portuguese language, a Romance language *** Portuguese dialects, variants of the Portuguese language ** Port ...
civil law system.


Legal status

In Hong Kong, the system has been implemented through the Basic Law of Hong Kong, which serves as the "mini-constitution" of the region, and consistent with the
Sino-British Joint Declaration The Sino-British Joint Declaration is a treaty between the governments of the United Kingdom and China signed in 1984 setting the conditions in which Hong Kong was transferred to Chinese control and for the governance of the territory after ...
. Similar arrangements are in place with Macau. Under the respective basic laws, the SARs have a high degree of autonomy and enjoy executive, legislative and independent judicial power, including that of final adjudication. They formulate their own monetary and financial policies, maintain their own currencies, formulate their own policies on education, culture, sports, social welfare system, etc. within the framework of the basic laws. As stipulated by the Basic Law, while the Central People's Government of the PRC is responsible for foreign affairs and defence in relation to the SARs, representatives of the government of the SARs may participate, as members of delegations of the PRC, in diplomatic negotiations that directly affect the Regions, and in other international organisations or conferences limited to states and affecting the region. For those international organisations and conferences not limited to states, the SARs may participate using the names in the form of ''Hong Kong, China'' and ''Macau, China''. As separate economic entities, both SARs of Hong Kong and Macau are members of the
World Trade Organization The World Trade Organization (WTO) is an intergovernmental organization that regulates and facilitates international trade. With effective cooperation in the United Nations System, governments use the organization to establish, revise, and ...
. Hong Kong is also one of the member economies of the
Asia-Pacific Economic Cooperation The Asia-Pacific Economic Cooperation (APEC ) is an inter-governmental forum for 21 member economies in the Pacific Rim that promotes free trade throughout the Asia-Pacific region.
. The Hong Kong Basic Law also provides constitutional protection on various fundamental human rights and freedoms; specifically, these rights are covered in the
International Covenant on Civil and Political Rights The International Covenant on Civil and Political Rights (ICCPR) is a multilateral treaty that commits nations to respect the civil and political rights of individuals, including the right to life, freedom of religion, freedom of speech, freed ...
, the International Covenant on Economic, Social and Cultural Rights, and international labour conventions which are implemented under Article 39 of the Hong Kong Basic Law and the Hong Kong Bill of Rights Ordinance. Nonetheless, the governments of the People's Republic of China and Hong Kong both consider the principle to have been successfully implemented, quoting official reports of both the United Kingdom and the United States. The Central People's Government in Beijing maintain relations with Hong Kong government through the
Liaison Office of the Central People's Government in the Hong Kong Special Administrative Region The Liaison Office of the Central People's Government in the Hong Kong Special Administrative Region (; abbr. LOCPG or 香港中聯辦) is the agency that represents the Chinese Central People's Government in Hong Kong. It replaced the New Ch ...
in Hong Kong. For Macau, Beijing uses the
Liaison Office of the Central People's Government in the Macao Special Administrative Region The Macau Liaison Office, officially known as the Liaison Office of the Central People's Government in the Macao Special Administrative Region ( (abbreviated: ); Portuguese: Gabinete de Ligação do Governo Central na RAEM) is the representative ...
in Macau. While the counterpart offices of the Hong Kong government for the Central People's Government in Beijing is the
Office of the Government of the Hong Kong Special Administrative Region in Beijing The Beijing Office, officially the Office of the Government of the Hong Kong Special Administrative Region of the People's Republic of China in Beijing (BJO), is the representative office of the Government of Hong Kong in the national capita ...
, and Macau government's office in Beijing is the
Office of the Macau Special Administrative Region in Beijing The Office of the Macau Special Administrative Region in Beijing (; pt, Delegação da Região Administrativa Especial de Macau em Pequim) is the representative office of Macau in the mainland area of the People's Republic of China. Its coun ...
.


Potential extension

Several high level members of the government have expressed a potential extension of the system beyond 2047 for Hong Kong. In January 2020,
Carrie Lam Carrie Lam Cheng Yuet-ngor ( Cheng; ; born 13 May 1957) is a retired Hong Kong politician who served as the 4th Chief Executive of Hong Kong from 2017 to 2022. She served as Chief Secretary for Administration between 2012 and 2017 and Se ...
stated that "My view is this: as long as we persist with the "One Country, Two Systems" principle, push forward the implementation of 'One Country, Two Systems' and have a full understanding and implementation of the principle... then we have adequate reason to believe that 'One Country, Two Systems' will be implemented smoothly and in the long term, and it will not change after 2047." Additionally, in a June 2020 online webinar to campaign for the National Security Law,
Zhang Xiaoming Zhang Xiaoming (; born 3 September 1963) is a Chinese politician. He was the director of the Liaison Office of the Central People's Government in Hong Kong and then of the Hong Kong and Macau Affairs Office, before being demoted to deputy dire ...
said that the National Security Law would ensure that the freedoms granted to the city can be extended beyond 2047. However, neither Carrie Lam or Zhang Xiaoming have promised such an extension or laid out concrete steps or goals in order for it to happen. In October 2021, Carrie Lam reiterated that she believed the system would be extended beyond 2047, stating "Anybody would seriously ask: why do we have to change it? But of course, something more concrete will have to come out later on to give the needed assurance about the continuation of the common law system, the monetary system, the professional recognition system, maybe some land leases." In March 2022,
Xia Baolong Xia Baolong (; born 2 December 1952) is a Chinese politician. Originally from Tianjin, Xia began his political career in the Communist Youth League. He served as the vice mayor of Tianjin, governor and Communist Party Secretary of Zhejiang pro ...
, head of the
Hong Kong and Macau Affairs Office The Hong Kong and Macau Affairs Office of the State Council is an administrative agency of the State Council of the People's Republic of China responsible for promoting cooperation and coordination of political, economic and cultural ties betwe ...
, said that after 2047, the "one country, two systems" could be extended by another 50 years, until 2097. In July 2022,
Leung Chun-ying Leung Chun-ying (; born 12 August 1954), also known as CY Leung, is a Hong Kong politician and chartered surveyor, who has served as vice-chairman of the National Committee of the Chinese People's Political Consultative Conference since M ...
, former chief executive, said that he expected the system to be extended past 2047. On 1 July 2022, President Xi Jinping made a promise that the system is a long-term policy.


Implementation in Hong Kong


Erosion of autonomy of Hong Kong

After Britain returned Hong Kong to China in 1997, Beijing promised that Hong Kong citizens would be free to elect their local government. However, the Basic Law does not have a clear timetable for when universal suffrage is to be achieved, ultimately stating that a full vote by the populace and universal suffrage must be reached before the end of the 50-year transition according to Article 45. Several incidents have caused portions of the Hong Kong public to call into question the PRC's pledge to allow a high degree of autonomy in Hong Kong. Some international observers and human rights organisations have expressed doubts about the future of the political freedoms currently enjoyed in Hong Kong. In the year after the handover, surveys showed high levels of satisfaction with Beijing's hands-off relationship with the former colony. The year before, the Provisional Legislative Council passed laws restricting the
right of abode The right of abode is an individual's freedom from immigration control in a particular country. A person who has the right of abode in a country does not need permission from the government to enter the country and can live and work there withou ...
, leading to a case brought against the government, which ended in a loss for the government in the Court of Final Appeal in 1999. The government then took its case to the National People's Congress. The legal establishment expressed its disapproval of the act Martin Lee described as "giving away" Hong Kong's autonomy with a silent march. Polls showed the events had depressed the public's confidence in the government, despite the fact that most were in favour of the government's stance over that of the court's. On 10 June 2014, Beijing released a new report asserting its authority over the territory. This ignited criticism from many people in Hong Kong, who said that the Communist leadership was reneging on its pledges to abide by the "one country, two systems" policy that allows for a democratic, autonomous Hong Kong under Beijing's rule. During the
2014 Hong Kong protests A series of sit-in street protests, often called the Umbrella Revolution and sometimes used interchangeably with Umbrella Movement, or Occupy Movement, occurred in Hong Kong from 26 September to 15 December 2014. The protests began after th ...
, students demanded more political freedom in direct response to the "831 decision" of the NPCSC. The participants demanded freedom of choice, electoral freedom, democracy and, in particular, they wanted to participate in the elections of the head of the administration of Hong Kong. The name "
umbrella movement The Umbrella Movement () was a political movement that emerged during the Hong Kong democracy protests of 2014. Its name arose from the use of umbrellas as a tool for passive resistance to the Hong Kong Police's use of pepper spray to dispe ...
" originated because the students protected themselves with umbrellas from the pepper spray of the police. Thus, umbrellas became the symbol of this movement. In 2016,
Joshua Wong Joshua Wong Chi-fung (; born 13 October 1996) is a Hong Kong activist and politician. He served as secretary-general of the pro-democracy party Demosistō until it disbanded following the implementation of the Hong Kong national security law ...
, Alex Chow and
Nathan Law Nathan Law Kwun-chung ( zh, link=no, t=羅冠聰; born 13 July 1993) is an activist and politician from Hong Kong. As a former student leader, he has been chairman of the Representative Council of the Lingnan University Students' Union (LUS ...
, student leaders of the protests, were charged for their roles in the protests and found guilty.


Moral and National Education controversy

It was officially announced in September 2012 that the Hong Kong government would introduce compulsory "national, moral and civic education" in all non-international primary and secondary schools to strengthen "national identity awareness and nurture patriotism towards China". According to an academic research paper, the current school curriculum in Hong Kong projects a "dual sense of identity: "Chineseness" and 'Hongkongesness'" and notably, this has created strong public activism by Hong Kong pre and post 1997. However, the new curriculum includes "general civic education" and lessons meant to increase students' appreciation of China. This announcement led to 10 days of protests, with up to 120,000 protesters each day, due to concerns of Hong Kong losing autonomy. In response, the chief executive at the time,
CY Leung Leung Chun-ying (; born 12 August 1954), also known as CY Leung, is a Hong Kong politician and chartered surveyor, who has served as vice-chairman of the National Committee of the Chinese People's Political Consultative Conference since Ma ...
, chose to remove the idea of compulsory teaching, meaning that schools could freely decide if they would teach the subject. Despite CY Leung's decision, new chief executive Carrie Lam, who took over on 1 July 2017, has prioritised the topic of national education, by placing importance on "instilling patriotism in pupils". Furthermore, in August 2017, Christine Choi Yuk-Lin was appointed by the government as the under-secretary of the Education Bureau. She "has former connections with the pro-Beijing Federation of Education Workers" (SCMP article A). This led to more than 17,000 people signing a petition opposing Yuk-lin having the position.
Chinese Communist Party The Chinese Communist Party (CCP), officially the Communist Party of China (CPC), is the founding and sole ruling party of the People's Republic of China (PRC). Under the leadership of Mao Zedong, the CCP emerged victorious in the Chinese Ci ...
general secretary Secretary is a title often used in organizations to indicate a person having a certain amount of authority, power, or importance in the organization. Secretaries announce important events and communicate to the organization. The term is derive ...
Xi Jinping Xi Jinping ( ; ; ; born 15 June 1953) is a Chinese politician who has served as the general secretary of the Chinese Communist Party (CCP) and chairman of the Central Military Commission (CMC), and thus as the paramount leader of China, ...
also announced during his visit to Hong Kong in July 2017 the need for an enhancement and boost of "national history and culture" in Hong Kong education.


Causeway Bay booksellers case

The disappearances of five staff at
Causeway Bay Books Causeway Bay Books (銅鑼灣書店) is an independent bookstore in Taipei, Taiwan which until December 2015 was an upstairs bookstore located in Causeway Bay, Hong Kong. The first bookstore in Hong Kong was popular with tourists from mai ...
– an independent publisher and bookstore – in October to December 2015 precipitated an international outcry as cross-border abductions were widely suspected. Although at least two of them disappeared in
mainland China "Mainland China" is a geopolitical term defined as the territory governed by the People's Republic of China (including islands like Hainan or Chongming), excluding dependent territories of the PRC, and other territories within Greater Chin ...
, one in
Thailand Thailand ( ), historically known as Siam () and officially the Kingdom of Thailand, is a country in Southeast Asia, located at the centre of the Indochinese Peninsula, spanning , with a population of almost 70 million. The country is b ...
, one member was last seen in Hong Kong, but apparently had found his way across the Chinese land border in Shenzhen without the necessary travel documents. The unprecedented disappearance of a person in Hong Kong, and the bizarre events surrounding it, shocked the city and crystallised international concern over the suspected abduction of Hong Kong citizens by
Chinese public security bureau A Public Security Bureau (PSB) () of a city or county, or Public Security Department (PSD) () of a province or autonomous region, in the People's Republic of China refers to a government office essentially acting as a police station or a local ...
officials and their likely rendition, in violation of several articles of the Basic Law and the one country, two systems principle. It was later confirmed that they are under detention in mainland China although most had reappeared in Hong Kong and cancelled their missing persons' reports with the police. On 16 June 2016, shortly after he returned to Hong Kong, Lam Wing-kee gave a long press conference in which he detailed the circumstances surrounding his eight-month detention, and describing how his confession and those of his associates had been scripted and stage-managed. Lam implicated the involvement of the
Central Investigation Team The Central Case Examination Group (; CCEG) was a special organization established in the People's Republic of China in 1966 under the aegis of the Politburo Standing Committee of the Chinese Communist Party to persecute those accused of "anti- pa ...
, which is under direct control of the highest level of the Beijing leadership. His revelations stunned Hong Kong and made headlines worldwide, prompting a flurry of counter-accusations and denials from mainland authorities and supporters.


Hong Kong National Party ban

On 17 July 2018, the
Hong Kong Police Force The Hong Kong Police Force (HKPF) is the primary law enforcement, investigative agency, and largest disciplined service under the Security Bureau of Hong Kong. The Royal Hong Kong Police Force (RHKPF) reverted to its former name after the t ...
served the party convener a notice under the Societies Ordinance, seeking to ban the Hong Kong National Party (HKNP) for sedition, on grounds of national security with respect to Chinese territorial integrity. The party and its convener Andy Chan submitted their case against being outlawed. Ten days later, in an unprecedented move, Secretary for Security John Lee on 24 September 2018 officially banned the party on national security grounds. The ban prohibited anyone who claims to be a HKNP member, or is found to provide aid to the party in any way, under the threat of being fined and jailed for up to two years. The definition of "providing aid" to the party and the two leaders were not made clear. Chan's lawyers wrote to the Department of Justice seeking an assurance that providing legal assistance to him would not be regarded as providing assistance to the HKNP, but that assurance was not forthcoming.


Victor Mallet controversy

In August, a controversy erupted in 2018 when the
Foreign Correspondents' Club of Hong Kong The Foreign Correspondents' Club (FCC) in Hong Kong is a members-only club and meeting place for the media, business and diplomatic community. It is located at 2 Lower Albert Road in Central, next to the Hong Kong Fringe Club, and they both occ ...
(FCC) hosted a lunchtime talk with Andy Chan, convener of the Hong Kong Independence Party (HKIP) to take place on 14 August. Victor Mallet, vice-chairman of the press organisation, chaired the session. The governments of China and Hong Kong had called for the cancellation of the talk, because the issue of independence supposedly crossed one of the "bottom lines" on national sovereignty. After a visit to Bangkok, Mallet was denied a working visa by the Hong Kong government. Mallet was subjected to a four-hour interrogation by immigration officers on his return from Thailand on Sunday 7 October before he was finally allowed to enter Hong Kong on a seven-day tourist visa. In the absence of an official explanation, Mallet's visa rejection was widely seen to be retribution for his role in chairing the Andy Chan talk which the FCC refused to call off. Secretary for Security John Lee insisted the ban on Mallet was unrelated to press freedom, but declined to explain the decision. The incident caused a furious debate over restrictions to freedoms that were supposedly protected by the
Sino-British Joint Declaration The Sino-British Joint Declaration is a treaty between the governments of the United Kingdom and China signed in 1984 setting the conditions in which Hong Kong was transferred to Chinese control and for the governance of the territory after ...
under "one country, two systems".


Extradition bill and Hong Kong 2019–2020 protests

In April 2019, an extradition bill was proposed in Hong Kong inciting mass protests. The new law identifies that those who are suspects of serious crimes could be sent to China. This was initiated due to a murder suspect fleeing from Taiwan to Hong Kong in 2018. He was accused of murdering his pregnant 20 year old girlfriend, thus Hong Kong authorities were asked by Taiwan to extradite the man. Hong Kong, however, did not concur with this demand and could not prosecute him as Hong Kong does not have any form of an extradition agreement with Taiwan. In terms of the Extradition Law, it was claimed that decisions would be made on a "case-by-case basis by the Chief Executive", in addition to Hong Kong courts making final decisions on extradition requests. For this reason, those accused of crimes based on politics or religion would not be extradited, and the new law would purely be "dealing with cross border crimes and transnational crimes" that carries a minimum seven-years sentence, as
Carrie Lam Carrie Lam Cheng Yuet-ngor ( Cheng; ; born 13 May 1957) is a retired Hong Kong politician who served as the 4th Chief Executive of Hong Kong from 2017 to 2022. She served as Chief Secretary for Administration between 2012 and 2017 and Se ...
stated in her speech on Monday 10 June. However, many Hong Kong people claim that this is another example of Hong Kong losing its autonomy. There has been criticism that this law would mean that suspects would be susceptible to many practices under the Chinese judicial system that is not present in the Hong Kong judicial system: arbitrary detention, unfair trial and torture. Michael DeGolyer, a researcher at Baptist University of Hong Kong, told Al Jazeera that Hong Kong people fear lack of judicial independence as the current judiciary system "is seen as guaranteeing a measure of protection from the government on the mainland". There has been a widespread response opposing the law: nationally and internationally. Criticism, petitions and protests have incorporated many parts of society, including doctors, lawyers, teachers and housewives. On 9 June there were an estimated 1 million people protesting across Hong Kong, making it the biggest protest since the handover. Additionally, concern was displayed internationally: in Britain, Canada, the European Union and the United States. The US congressional commission argued in May 2019 that the extradition bill makes "Hong Kong more susceptible to China's political coercion and further erodes Hong Kong's autonomy". China's foreign ministry has rebutted these concerns by claiming them "attempts to politicise the Hong Kong government proposal and interference in China's internal affairs". Due to this negative response nationally and internationally, on 4 September 2019, Carrie Lam formally announced that the extradition bill would be withdrawn. Despite this, fear of the loss of Hong Kong autonomy remains. Protests continued until the outbreak of the
COVID-19 pandemic The COVID-19 pandemic, also known as the coronavirus pandemic, is an ongoing global pandemic of coronavirus disease 2019 (COVID-19) caused by severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). The novel virus was first identified ...
in January 2020, and are predicted to continue once the pandemic is under control in Hong Kong.


2020 national security legislation

A draft national security bill was submitted on 22 May 2020 to China's national parliament, the National People's Congress. In accordance with the one country, two systems formula, Hong Kong's basic law requires the Hong Kong legislature to ratify national security to prevent sedition, secession and foreign interference. The Chinese central government is now bypassing the HKSAR to directly legislate. A National People's Congress official reported as saying it was exercising "constitutional power" to create a new legal framework and enforcement mechanism to guarantee national security in Hong Kong. On 30 June 2020, the Standing Committee of the National People's Congress (NPCSC) passed the national security law for Hong Kong unanimously and listed it under Annex III of the Basic Law, bypassing Hong Kong approval. The Hong Kong Bar Association (HKBA) disputed the constitutionality of enacting the law through inclusion in Annex III of the Basic Law in May 2020. On 30 May 2020, the president of the United States,
Donald J. Trump Donald John Trump (born June 14, 1946) is an American politician, media personality, and businessman who served as the 45th president of the United States from 2017 to 2021. Trump graduated from the Wharton School of the University of Pe ...
, in a
White House The White House is the official residence and workplace of the president of the United States. It is located at 1600 Pennsylvania Avenue Northwest, Washington, D.C., NW in Washington, D.C., and has been the residence of every U.S. preside ...
press conference, officially declared that the United States would be ending special treatments afforded to Hong Kong as outlined in the United States-Hong Kong Policy Act, due to China replacing the promised formula of "one country, two systems" with "one country, one system", and threatened that the United States would take further actions on Hong Kong in response to the national security law. On 14 July 2020, President Trump signed
Executive Order 13936 Executive Order 13936, entitled "The President’s Executive Order on Hong Kong Normalization", is an executive order signed by U.S. President Donald Trump on July 14, 2020. On the same day Trump had signed into law Hong Kong Autonomy Act, one ...
, pursuant to the Hong Kong Autonomy Act passed by the US Congress, ending Hong Kong's special trade privileges. According to Victoria Tin-bor Hui, writing in ''
The Diplomat ''The Diplomat'' is an international online news magazine covering politics, society, and culture in the Indo-Pacific region. It is based in Washington, D.C. It was originally an Australian bi-monthly print magazine, founded by Minh Bui Jones ...
'', the national security legislation is being used to erode civil and legal protections on the way to "establishing a
police state A police state describes a state where its government institutions exercise an extreme level of control over civil society and liberties. There is typically little or no distinction between the law and the exercise of political power by the ...
" in Hong Kong.


Implementation in Macau


Macau and China relations

Macau has not seen outbreaks of protests and civil unrest that have occurred in Hong Kong. According to
Jason Chao Jason Chao Teng Hei (; born December 12, 1986) was born in Macau. Chao is a social activist and LGBT rights campaigner. He was President of the New Macau Association and Director of the satirical newspaper '' Macau Concealer'', one of the few onl ...
, a former president of the
New Macau Association The New Macau Association (AMN) is a major pro-democratic political party in the Chinese Special Administrative Region of Macau. The party was established in 1992 and the founding chairman was António Ng Kuok Cheong, who departed from the the ...
(a pro-democracy party), Macau differed from Hong Kong as Macau does not wish for freedom and autonomy. Instead, the majority of Macau's population are pro-China. A reason for this is because approximately half of the 600,000 people living in Macau are Chinese immigrants. In December 2019,
Li Zhanshu Li Zhanshu (; born August 30, 1950) is a Chinese politician, and the current outgoing chairman of the Standing Committee of the National People's Congress, the Chinese Speaker. He was the third-ranking member of the Politburo Standing Committ ...
, chairman of the NPCSC, claimed that there is a "strong sense of international identity" in Macau. In Chinese Communist Party general secretary
Xi Jinping Xi Jinping ( ; ; ; born 15 June 1953) is a Chinese politician who has served as the general secretary of the Chinese Communist Party (CCP) and chairman of the Central Military Commission (CMC), and thus as the paramount leader of China, ...
's first official speech in Macau in December 2019 marking the 20th anniversary, he proclaimed Macau as "a gorgeous chapter in the short history of the one country, two systems experiment". Chief executive of Macau,
Ho Iat Seng Ho Iat-seng (; born 12 June 1957) is a Macanese politician serving as the 3rd and current Chief Executive of Macau since December 2019. Early life Ho studied at , Macau. In 1992, he studied electronic engineering and economics at Zhejiang Uni ...
, said: "Macau will be an example of China's reunification," and Xi has agreed, by placing emphasis on the "Macau Model" as Macau has correctly followed the "one country, two system" agreement. As a reward for Macau's peaceful behaviour and lack of anti-government protests, Xi Jinping has given Macau more Chinese land from
Hengqin Hengqin (, pt, Ilha da Montanha) is an island in Zhuhai, a prefecture-level city and special economic zone in Guangdong Province of the People's Republic of China. It has a population of about 3,000. Parts of Hengqin were leased to Macau by t ...
Island. This is to enable Macau to further develop their education and healthcare system, in addition to physically integrating Macau more with China.


Proposed application onto Taiwan

The "one country, two systems" principle has also been proposed by the PRC government for
Taiwan Taiwan, officially the Republic of China (ROC), is a country in East Asia, at the junction of the East and South China Seas in the northwestern Pacific Ocean, with the People's Republic of China (PRC) to the northwest, Japan to the northe ...
, but the
government of the Republic of China The Government of the Republic of China, is the national government of the Republic of China whose ''de facto'' territory currently consists of Taiwan, Penghu, Kinmen, Matsu and other island groups in the "free area". Governed by the De ...
has refused this suggestion. (It has also been previously claimed that the system was originally designed for Taiwan in order for it to be unified with the PRC). Although "one country, two systems" guarantees that Hong Kong's economic and
political system In political science, a political system means the type of political organization that can be recognized, observed or otherwise declared by a state. It defines the process for making official government decisions. It usually comprizes the govern ...
s would not be changed for 50 years after the British handover in 1997, the
Mainland Affairs Council The Mainland Affairs Council (MAC) is a cabinet-level administrative agency under the Executive Yuan of the Republic of China in Taiwan. The MAC is responsible for the planning, development, and implementation of the cross-strait relations po ...
of the Republic of China has cited 218 cases between 1997 and 2007 in which they claim the PRC has breached the right of the people of Hong Kong to self-rule and severely intervened in the judicial system as well as freedom of speech. A new policy based on the
1992 Consensus The 1992 Consensus is a political term referring to the alleged outcome of a meeting in 1992 between the semiofficial representatives of the People's Republic of China (PRC) of mainland China and the Republic of China (ROC) of Taiwan. They are of ...
was emphasised during the
2005 Pan-Blue visits to mainland China 5 (five) is a number, numeral and digit. It is the natural number, and cardinal number, following 4 and preceding 6, and is a prime number. It has attained significance throughout history in part because typical humans have five digits on e ...
in April 2005 as well as subsequent major cross-strait exchanges under President
Ma Ying-jeou Ma Ying-jeou ( zh, 馬英九, born 13 July 1950) is a Hong Kong-born Taiwanese politician who served as president of the Republic of China from 2008 to 2016. Previously, he served as justice minister from 1993 to 1996 and mayor of Taipei from 1 ...
, whose pro-unification
Kuomintang The Kuomintang (KMT), also referred to as the Guomindang (GMD), the Nationalist Party of China (NPC) or the Chinese Nationalist Party (CNP), is a major political party in the Republic of China, initially on the Chinese mainland and in Tai ...
party won the
2008 Republic of China presidential election Presidential elections were held in Taiwan on 22 March 2008. Kuomintang (KMT) nominee Ma Ying-jeou won with 58% of the vote, ending eight years of Democratic Progressive Party (DPP) rule. Along with the 2008 legislative election, Ma's landslide ...
. During his visit to Beijing in March 2012, former
Kuomintang The Kuomintang (KMT), also referred to as the Guomindang (GMD), the Nationalist Party of China (NPC) or the Chinese Nationalist Party (CNP), is a major political party in the Republic of China, initially on the Chinese mainland and in Tai ...
(KMT) Chairman
Wu Po-hsiung Wu Po-hsiung (; born 19 June 1939) is a Taiwanese politician who is a former chairman of the Kuomintang (KMT). He has been the Interior Minister (1984-1988), Mayor of Taipei (1988–1990), Secretary-General to the President (1991–1996), and ...
proposed a "one country, two areas" () framework to govern
cross-strait relations Cross-Strait relations (sometimes called Mainland–Taiwan relations, or Taiwan-China relations) are the relations between China (officially the People's Republic of China) and Taiwan (officially the Republic of China). The relationship ...
, though this term did not become widely adopted. In January 2019,
Xi Jinping Xi Jinping ( ; ; ; born 15 June 1953) is a Chinese politician who has served as the general secretary of the Chinese Communist Party (CCP) and chairman of the Central Military Commission (CMC), and thus as the paramount leader of China, ...
,
General Secretary of the Chinese Communist Party The general secretary of the Chinese Communist Party () is the head of the Chinese Communist Party (CCP), the sole ruling party of the People's Republic of China (PRC). Since 1989, the CCP general secretary has been the paramount leader ...
(CCP), had announced an open letter to Taiwan proposing a "one country, two systems" formula for eventual unification. President
Tsai Ing-wen Tsai Ing-wen (; born 31 August 1956) is a Taiwanese politician serving as president of the Republic of China (Taiwan) since 2016. A member of the Democratic Progressive Party (DPP), Tsai is the first female president of Taiwan. She served a ...
responded to Xi in a January 2019 speech by stating that Taiwan rejected "one country, two systems" and that because Beijing equated the
1992 Consensus The 1992 Consensus is a political term referring to the alleged outcome of a meeting in 1992 between the semiofficial representatives of the People's Republic of China (PRC) of mainland China and the Republic of China (ROC) of Taiwan. They are of ...
with "one country, two systems", Taiwan rejected the 1992 Consensus as well. Tsai expressed her solidarity with Hong Kong protesters, remarking that Taiwan's democracy was hard-earned and had to be guarded and renewed. Pledging that as long as she was Taiwan's president, she would never accept "one country, two systems", Tsai cited what she considered to be the constant and rapid deterioration of Hong Kong's democracy over the course of 20 years. Following the landslide defeat of the KMT in the
2020 Taiwanese presidential election Presidential elections were held in Taiwan on 11 January 2020 along with the 2020 Taiwanese legislative election, 10th Legislative Yuan election. Incumbent president Tsai Ing-wen and former Premier of the Republic of China, premier William Lai o ...
, KMT chairman Johnny Chiang rejected the "one country, two systems" as a feasible model for Taiwan. In 2021 the KMT platform under newly elected chairman
Eric Chu Eric Chu Li-luan (; born on 7 June 1961) is a Taiwanese politician. He was born into a political family with strong Kuomintang (KMT) ties, and served as Vice Premier of the Republic of China, under Premier Wu Den-yih. Prior to this, Chu served ...
also continued to include the 1992 consensus while rejecting "one country, two systems".


Comparison to status of Tibet

Jiang (2008) notes that the concept of "one country, two systems" is based on the
Seventeen Point Agreement for the Peaceful Liberation of Tibet The Seventeen Point Agreement is a short form of the Agreement of the Central People's Government and the Local Government of Tibet on Measures for the Peaceful Liberation of Tibet, ( zh, 中央人民政府和西藏地方政府关于和平解放 ...
signed in 1951, and that its mechanism is similar to how the Qing emperor integrated new territories it had conquered by permitting local elites in these regions to continue to enjoy power for a time and to exercise autonomy without apparently threatening distinct local customs. As the concept was merely a "tactical and transitional arrangement", a point of view argues that the territory of Hong Kong will gradually experience the same fate as Tibet since 1959 – forced assimilation and tight direct control by the central government. Over time, full assimilation, and abolition of local autonomy, would take place in a manner "illustrative of a similar Chinese imperial expansionist mentalité".Hung, Ho-fung
"Three Views of Local Consciousness in Hong Kong"
. ''The Asia-Pacific Journal'', Vol. 12; Issue 44, No. 1; 3 November 2014.
The
14th Dalai Lama The 14th Dalai Lama (spiritual name Jetsun Jamphel Ngawang Lobsang Yeshe Tenzin Gyatso, known as Tenzin Gyatso (Tibetan: བསྟན་འཛིན་རྒྱ་མཚོ་, Wylie: ''bsTan-'dzin rgya-mtsho''); né Lhamo Thondup), known as ...
's 2005 proposal for "high-level autonomy" for
Tibet Tibet (; ''Böd''; ) is a region in East Asia, covering much of the Tibetan Plateau and spanning about . It is the traditional homeland of the Tibetan people. Also resident on the plateau are some other ethnic groups such as Monpa people, ...
, evolved from a position of advocating Tibetan independence, has been compared to "one country, two systems". He has said that his proposals should be acceptable to China because "one country, two systems" is accommodated for in the Chinese Constitution. State media rejected this claim, pointing out that "one country, two systems" was designed for the capitalist social systems of Hong Kong and Macau, which had never existed in Tibet. In 2012, Dalai Lama mentioned again that the
Seventeen Point Agreement The Seventeen Point Agreement is a short form of the Agreement of the Central People's Government and the Local Government of Tibet on Measures for the Peaceful Liberation of Tibet, ( zh, 中央人民政府和西藏地方政府关于和平解放 ...
was signed in the spirit of "one country, two systems".


One country, two systems proposals for other countries

Muhammad Cohen, writing for ''
Asia Times ''Asia Times'' (), formerly known as ''Asia Times Online'', is a Hong Kong-based English language news media publishing group, covering politics, economics, business, and culture from an Asian perspective. ''Asia Times'' publishes in English an ...
'', suggests the "one country, two systems" formula is a possible solution to the
Israeli–Palestinian conflict The Israeli–Palestinian conflict is one of the world's most enduring conflicts, beginning in the mid-20th century. Various attempts have been made to resolve the conflict as part of the Israeli–Palestinian peace process, alongside other eff ...
. North Korea suggests the "one country, two systems" formula to bring about
Korean reunification Korean reunification () is the potential reunification of the Democratic People's Republic of Korea and the Republic of Korea into a single Korean sovereign state. The process towards reunification was started by the June 15th North–South Jo ...
, through a confederation of two systems within one country. China has also promoted the idea; the difference between North Korea's motivation and China's is that North Korea seeks to maintain two separate governments, while China seeks gradual unification as it wishes to bring stability to the Korean peninsula with one centralised government. Irish Foreign Minister
Simon Coveney Simon Coveney (born 16 June 1972) is an Irish Fine Gael politician who has served as Minister for Enterprise, Trade and Employment since December 2022 and Deputy Leader of Fine Gael since 2017. He previously served as Minister for Foreign Aff ...
said the arrangement linking Hong Kong with China could be a possible solution for addressing the fate of
Northern Ireland Northern Ireland ( ga, Tuaisceart Éireann ; sco, label=Ulster-Scots, Norlin Airlann) is a part of the United Kingdom, situated in the north-east of the island of Ireland, that is variously described as a country, province or region. North ...
after
Brexit Brexit (; a portmanteau of "British exit") was the withdrawal of the United Kingdom (UK) from the European Union (EU) at 23:00 GMT on 31 January 2020 (00:00 1 February 2020 CET).The UK also left the European Atomic Energy Community (EAE ...
. The border between the EU member state Republic of Ireland and British-ruled Northern Ireland is becoming an increasing concern in talks with the United Kingdom, with
Dublin Dublin (; , or ) is the capital and largest city of Ireland. On a bay at the mouth of the River Liffey, it is in the province of Leinster, bordered on the south by the Dublin Mountains, a part of the Wicklow Mountains range. At the 2016 ...
demanding that the frontier remain completely open, to avoid endangering the
peace process A peace process is the set of sociopolitical negotiations, agreements and actions that aim to solve a specific armed conflict. Definitions Prior to an armed conflict occurring, peace processes can include the prevention of an intra-state or in ...
.Irish minister suggests "Hong Kong solution" for post-Brexit Northern Ireland
, AFP, '' South China Morning Post'', 22 November 2017


See also

*
1992 consensus The 1992 Consensus is a political term referring to the alleged outcome of a meeting in 1992 between the semiofficial representatives of the People's Republic of China (PRC) of mainland China and the Republic of China (ROC) of Taiwan. They are of ...
* Administrative divisions of the People's Republic of China *
Autonomous administrative division An autonomous administrative division (also referred to as an autonomous area, entity, unit, region, subdivision, or territory) is a subnational administrative division or internal territory of a sovereign state that has a degree of autonomy� ...
*
Democracy in China The debate over democracy in China has been a major ideological battleground in Chinese politics since the 19th century. China is not a Western-style liberal democracy. The Chinese government and the Chinese Communist Party (CCP) state that C ...
*
Federacy A federacy is a form of government where one or several substate units enjoy considerably more independence than the majority of the substate units. To some extent, such an arrangement can be considered to be similar to asymmetric federalism ...
* Hong Kong–Mainland conflict *
Law of Hong Kong The law of the Hong Kong Special Administrative Region has its foundation in the English common law system, inherited from being a former British colony and dependent territory. There are several sources of law, the primary ones being statute ...
*
Special Economic Zone A special economic zone (SEZ) is an area in which the business and trade laws are different from the rest of the country. SEZs are located within a country's national borders, and their aims include increasing trade balance, employment, increas ...


References

Jonathan Kaiman
Hong Kong's umbrella revolution – the Guardian briefing
, ''
The Guardian ''The Guardian'' is a British daily newspaper A newspaper is a periodical publication containing written information about current events and is often typed in black ink with a white or gray background. Newspapers can cover a wide ...
'', 30 September 2014, retrieved on 23 July 2017


Further reading

* {{Cross-Strait relations Federalism in China Politics of Hong Kong Politics of China Law of Hong Kong Government of Macau Politics of Macau Government of Hong Kong Macau law Ideology of the Chinese Communist Party