How China is stepping into the cultural repatriation void left by a retreating US

As one of the biggest targets of wartime looting in centuries past, China is now positioning itself as a global pioneer in repatriating lost cultural artefacts. In this article, the second in a two-part series, Xinlu Liang looks at how China is wielding law, diplomacy and a Global South coalition to rewrite the rules of restitution, filling a void left by a retreating US. In January, as the United States was withdrawing from a raft of heritage and science bodies around the world, China was testing a new international model for cultural repatriation. The effort was spearheaded by Chinese researchers and Japanese activists who came together in a lecture hall in Shanghai University to call for the return of a 1,300-year-old national treasure, the Tang Honglu Well Stele. The stele was stolen from China in wartime more than a century ago and, as the advocates made their case, officials from the National Cultural Heritage Administration of China watched on – the clearest signal yet of Beijing’s intention to press Tokyo on the issue. The demand for the stele’s return is grounded in extensive research, support in both countries and a fresh legal framework, marking a shift from the past when repatriation calls were largely made by lone voices outside officialdom with little professional documentation. The case reflects China’s efforts to become not just a petitioner but an ambitious rules maker in global heritage restitution through a sophisticated, multipronged combination of domestic legislation, bilateral agreements, law enforcement cooperation and Global South alliances. Yet, analysts caution, China’s ambitions may be hindered by oversimplified nationalist narratives, geopolitical tensions and the limitations of non-binding international conventions. The modern chapter of China’s repatriation efforts began in frustration. In 2009, Christie’s Paris ignored Beijing’s requests to prevent the auction of two bronze fountainheads in the shape of Chinese zodiac animals, which had been looted from Beijing’s Old Summer Palace by Anglo-French forces in 1860. Huo Zhengxin, then a young scholar of international law, was puzzled. The fountainheads were among an estimated 1.5 million Chinese artefacts illegally smuggled abroad – most taken during the chaos between the mid-19th and early 20th centuries. “I kept thinking: why weren’t they returned?” recalled Huo, now a professor at China University of Political Science and Law, in Beijing. Huo’s research revealed an answer to his question – for a long time, China’s efforts were reactive and fragmented. Constrained by existing international rules, restitution often relied on donations, sympathetic allies or costly “patriotic buy-backs” at auction that inadvertently lent legitimacy to a murky market. These returns were hard-won victories but they were also “passive and piecemeal”, said Huo, who also serves as an observer to the 1970 Unesco Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property. But then came a global wave of decolonisation, beginning in Burkina Faso in 2017 when French President Emmanuel Macron declared: “In the next five years, I want the conditions to be met for the temporary or permanent restitution of African heritage to Africa.” To drive the point home, the Elysee announced later that “African heritage can no longer be the prisoner of European museums”. The speech jolted the West into a new moral consensus – that colonial-era plunder, long shielded by museum walls, was no longer defensible – and triggered a wave of restitutions across Europe and North America. Most notably, more than 100 Benin Bronzes were returned to Nigeria from the Netherlands. That momentum appears to have waned in recent years, according to Chika Okeke-Agulu, a Princeton University professor of art, archaeology and African-American studies. “In fact, loud calls during the Black Lives Matter movement to decolonise museums have been silenced,” he said. Unesco restitution mediator Andrzej Jakubowski said a global rightward political shift had fostered “increased scepticism” towards decolonisation, framing it as “ideologically driven”. This had led to diminished political will, tighter scrutiny of museum practices and a preference for caution, said Jakubowski, an assistant law professor at the Polish Academy of Sciences, in Warsaw. However, others argue the movement has not retreated but transformed. Simon Li, a Hong Kong-based public historian and senior fellow at the University of Southern California’s Shoah Foundation, said that “silence does not always mean retreat”, adding that activity had shifted from protests to patient, technical work: provenance research, academic collaboration and quiet diplomacy. Unesco echoed this view, noting a “steadily growing global momentum” marked by “increasing dialogues and cooperation” between countries of origin and holding institutions. Many nations were developing innovative mechanisms that served not just restitution but also “cultural exchange, scientific cooperation and community empowerment”, Unesco said. Among those nations is China, which has positioned itself as a guardian of heritage. Over the past decade, China has assembled a systematic toolkit – bolstered by its growing geopolitical clout and heavy investment in repatriation infrastructure. China’s push to reshape global restitution norms began in 2014 with the Dunhuang Recommendation, which urged states to join Unesco treaties, create databases, and use scientific evidence for archaeological claims. Under President Xi Jinping’s vision for making China a “cultural superpower”, the National Cultural Heritage Administration also established a dedicated relic-recovery office in 2019. A revised Cultural Relics Protection Law, which took effect in March 2025, asserted a permanent, non-time-limited right to reclaim looted cultural property. The campaign culminated in the 2024 Qingdao Recommendations. Co-signed by 18 other nations from Asia, Africa and Latin America, the document moves beyond the strict legalities of the 1970 Unesco convention, which lacks retroactive force, into ethical territory, explicitly calling for the return of objects “removed from colonial contexts or acquired by other unjustifiable or unethical means”. Huo, who led the drafting, pointed to the US’ return of the 2,300-year-old Zidanku Silk Manuscripts last May as a successful outcome under this new framework. In China, repatriation has been framed as part of “cultural security” and a project aimed at “stabilising historical interpretation in support of sovereignty, cultural continuity and national rejuvenation”, according to Neil Schmid, the first Western scholar to work at the Dunhuang Academy in northwest China’s Gansu province. Schmid said the efforts were “a legitimate form of heritage diplomacy”, and one – crucially – “aimed at renegotiating China’s position within a global cultural order that was largely shaped without the country’s consent”. Jakubowski said China’s approach had shifted the discussion from rigid questions of legal ownership towards ethics, provenance and dialogue – areas in which Western institutions were showing increasing openness. And by invoking concepts such as “historical injustice” and “ethical responsibility”, China was aligning itself with Western decolonisation debates, while amplifying voices from the Global South including those of Egypt and Nigeria, he said. Last May, China was for the first time elected chair of the Meeting of States Parties to the 1970 Unesco Convention, a role granting it “further agenda-setting power”, according to Huo, who called the appointment “recognition of China’s long-standing contributions”. The significance was amplified, he noted, by Washington’s announcement in July that it would withdraw from Unesco for a third time, by the end of 2026. Unesco has acknowledged China as an “active and constructive partner” in combating the illicit trafficking of cultural property, but stressed that ethical restitution required collective effort and could not be achieved by any one country “alone” – a challenge Beijing has sought to meet with a systematic, multipronged approach. China now employs four main strategies based on an artefact’s provenance and legal status: law enforcement cooperation, transnational litigation, diplomatic negotiation, and donations or purchases. Between 2012 and late 2023, China repatriated more than 2,310 relics in 59 batches. According to Liu Hao, an associate professor at Shandong University specialising in international cultural heritage law, China has increasingly prioritised law enforcement cooperation. He added that purchases and donations played a smaller role, while diplomatic negotiation and transnational litigation could become “tipping points” in the future. Law enforcement is preferred for contemporary crimes. A landmark example occurred in 2019, when Beijing mounted a rapid campaign to recover eight Zhou dynasty (c1046-256BC) bronze vessels that had appeared in an auction catalogue in Tokyo. The heritage administration filed an urgent diplomatic petition backed by a comprehensive dossier of academic and police evidence compiled by Huo’s team. The auction was cancelled and the bronzes returned within six months. Transnational civil litigation remained arduous with few successes, Liu said, as domestic laws in many countries shielded state-held relics from de-accession, while private relics required Chinese plaintiffs to meet high evidentiary burdens. The donation route leverages soft power and economic gravity. Dutch restitution expert Jos van Beurden noted that countries in possession of lost Chinese relics “increasingly need [China] and have therefore become more lenient towards it in recent decades”. “This is related to politics and economics,” he added. He cited the 2013 donation of Old Summer Palace bronze zodiac animal heads by French billionaire François-Henri Pinault, which coincided with Christie’s, one of his companies, securing a licence to operate independently in mainland China. The sculptures were the ones that had puzzled Huo in 2009 when they had gone up for auction at Christie’s Paris. Back then, Cai Mingchao, an adviser to China’s National Treasures Fund, bid successfully for them and then refused to pay on patriotic grounds. Pinault later quietly acquired the pieces, before formally presenting them to Beijing. The most impactful approach now happens in quiet diplomatic channels. In 2009, China signed a memorandum of understanding with the US that has been renewed three times, even as diplomatic relations have cooled. The agreement restricts US imports of broad categories of Chinese archaeological material and has facilitated the return of more than 500 artefacts, including 361 seized by the FBI and repatriated in 2019 – the largest single batch of items returned from the US to China under the agreement. Schmid said the collaborations showed that cultural property, while “relatively insulated” from high-level politics, could function as “a rare bridge” amid Sino-US tensions. By the end of 2023, China had signed similar bilateral agreements with 26 nations. By having a frank reckoning about the Cultural Revolution, China will make a stronger case that it understands what cultural destruction can do to a society Rana Mitter, historian That progress, however, has not insulated Beijing from questions about its credibility as a steward of heritage at home. Critics argue its repatriation narrative flattens complex histories – a charge given weight by Justin Jacobs, a historian at American University, in Washington, who said artefacts acquired through unjustified violence constituted “only a tiny proportion” of Western collections. With many having left China through trade, gifts or legal export, the country’s “oversimplified” narrative risked undermining its credibility by serving “overtly politicised agendas”, he added. A 2023 viral Chinese short film, Escape from the British Museum, captured public imagination by personifying a jade teapot in the museum as a homesick young woman yearning to return to China. Widely mourned as “looted” by Chinese nationalists, the teapot in question had actually been made in 2011 by a Chinese master and voluntarily sold to the British Museum in 2017. At Dunhuang, Schmid acknowledged that while manuscripts from the nearby Mogao Caves – a Unesco World Heritage site – had left China through various channels, foreign explorers had acquired them from local custodians under “asymmetries of power and weak state oversight”. Though official Chinese policy distinguished between looted and legally traded items, he added, “this distinction is often blurred in popular narratives in favour of a unified moral story”. Repatriation tends to succeed when treated as professional or legal rectification, and stalls when it becomes enmeshed in sovereignty and historical grievances Neil Schmid, Silk Road scholar Others have urged China to confront its own history, particularly the Cultural Revolution, when countless cultural treasures were destroyed. “By having a frank reckoning about that period, China will make a stronger case that it understands what cultural destruction can do to a society,” said Rana Mitter, S.T. Lee chair in US-Asia relations at the Harvard Kennedy School. Jakubowski agreed that China would need to establish transparent procedures for addressing past injustices, thereby ensuring “effective museum oversight”. But, he cautioned, China’s own institutional failings should not become a reason to withhold repatriation, which would effectively penalise the very communities the process was meant to serve. When it comes to navigating such complexity, “rigorous provenance research becomes an asset rather than a liability”, said Jakubowski, an arbitrator at the Court of Arbitration for Art in The Hague. Building ironclad evidence chains remains critical yet immensely difficult. For instance, Chinese and Japanese scholars spent more than 30 years painstakingly compiling archival evidence of the 1,300-year-old Tang Honglu Well Stele’s journey from northeast China to Tokyo’s Imperial Palace, before making their call in January. Yet for most looted items, Huo said, records were scarce and the art market laundered provenance. Legal tools also have limits. As the 1970 Unesco convention is not retroactive, it does not cover artefacts looted during the opium wars or World War II. Soft law instruments like the Qingdao Recommendations lack enforcement mechanisms and rely on moral persuasion. Their vague language and a lack of independent arbitration frequently produce unpredictable outcomes, pushing disputes towards politically sensitive bilateral talks or domestic courts, according to Liu. Geopolitics further complicates matters. Nowhere is this clearer than in China’s stand-off with Japan, which seized millions of artefacts during wartime invasions. Sino-Japanese repatriation cases cannot be disentangled from broader questions of war guilt, compensation and historical memory. Huo urged China – as the world’s most heavily looted nation, according to some estimates, as well as a global power – to take the lead on recovering relics from Japan. He noted, however, that the political will for landmark historical reconciliation of the kind seen in recent European returns of African artefacts was absent in Tokyo. Differing legal systems and competing national interests across Asia had also hindered the development of a unified regional framework, he said. The Tang Honglu Well Stele case is particularly fraught, as its display in the Tokyo Imperial Palace “unfortunately elevates the dispute from issues of provenance to something highly symbolic, making compromise far more difficult”, according to Schmid. “Repatriation tends to succeed when treated as professional or legal rectification, and stalls when it becomes enmeshed in sovereignty and historical grievances,” he added. For China, the ultimate success of repatriation is measured not in the number of objects returned but by how those returns strengthen relationships and transform artefacts into “bridges” of shared meaning, rather than “boundaries”, according to Li, the public historian. When cultural artefacts were returned and “recontextualised” through research and public education, he noted, restitution shifted from an act of nationalism to one of narrative justice. “China’s credibility rests on its ability to separate restitution from retribution, and to frame its actions as participation in an evolving global standard rather than a solitary national crusade,” he said.

How China is stepping into the cultural repatriation void left by a retreating US

.css-1c6uqr6{color:inherit;font-weight:inherit;font-size:inherit;font-family:inherit;line-height:inherit;overflow-wrap:break-word;}As the United States steps back from cultural governance, China aims to reshape how the world reclaims looted heritage – with Japan its biggest test

As the United States steps back from cultural governance, China aims to reshape how the world reclaims looted heritage – with Japan its biggest test