Understanding Chinese ‘Four Sha’ Claim in the South China Sea: Strategic Objectives Through New Subtlety

“A piece of paper that is destined to come to naught.”¹

 -Liu Zhenmin, China's Vice Foreign Minister

“We do not claim an inch of land that does not belong to us, but we won’t give up any patch that is ours.”²

-The People’s Daily, 13 July 2016

Abstract: The South China Sea (SCS), a strategic maritime zone rich in natural resources and vital shipping lanes, has long been a flashpoint for territorial disputes involving China and several Southeast Asian nations. China's historic 'Nine-Dash Line' claim, which encompassed nearly 90% of the SCS, was invalidated by the Permanent Court of Arbitration (PCA) at The Hague in 2016. In response, China introduced a new, seemingly moderate 'Four Sha' (‘sha’ is sand in Mandarin) claim, asserting sovereignty over four island groups: Dongsha, Xisha, Zhongsha and Nansha. This subtle legal repositioning masks strategic intent to consolidate control while evading international backlash. Recent tensions, particularly with the Philippines over the Scarborough Shoal, underscore this shift. Skirmishes, including near-collisions and unauthorised Chinese maritime activities within the Philippines’ EEZ, continue to heighten regional instability. This evolving narrative reflects China’s strategic adaptation in the face of legal challenges and diplomatic pressure. The ‘Four Sha’ doctrine attempts to reframe maritime entitlements by treating dispersed islands as unified archipelagic entities, an approach inconsistent with UNCLOS provisions. Meanwhile, ASEAN's fragmented stance has limited the bloc’s ability to mount a collective response.

Introduction

The epigraphs are representative of the official reactions of the Chinese Government to the ruling of the Permanent Court of Arbitration, Hague, on 12 July 2016, on a Philippines complaint of a dispute between China and the Philippines over Scarborough Shoal in the South China Sea (SCS). In turn, the response from Manila was as below:

"The Philippines is firm in its position that China’s claims based on the ‘Four Sha’ are not only unlawful but also undermine regional stability and security. We call on the international community to stand in solidarity with us in upholding the rule of law in the South China Sea."³

 - Enrique Manalo, Philippines Foreign Secretary 12 July 2020

This reaction by Philippines highlights that ‘all is not well’ in the SCS. There is a need for the international community to understand the issue. Hence, there is a compelling necessity to study and analyse the Chinese ‘Four Sha’ claim in the South China Sea.

Despite its rich maritime history, China remained largely continental in its outlook throughout the 19th and 20th centuries, primarily due to security concerns along its land borders. By the late 20th century, after settling many territorial disputes, it turned its attention to maritime areas, particularly in the South China Sea (SCS). This semi-enclosed sea, bordered by multiple Asian nations, holds immense strategic significance due to its vast economic resources and position along dense shipping lanes. This hardly needs elaboration for this journal’s readership. China has aggressively pursued claims over nearly 90% of the SCS, citing historical records such as the 600 year old Book of Maritime Routes and its 1947 "Nine-Dash Line" map, which has been widely contested by neighbouring countries and ruled legally baseless by the UN tribunal at The Hague.⁴ Despite the verdict, China dismissed the ruling and escalated military activities in the region. This paper aims to analyse the ‘Four Sha claim’ by China replacing its ‘Nine-Dash line claim’ over the South China Sea.

Chinese Nine-Dash Line Claim in SCS

11- Dash Line Claim. The nationalist Kuomintang government in China, formed in 1947, took baby steps to strengthen the country emerging from defeat in the 2^nd World War.⁵ As parts of its efforts to strengthen its boundaries, the Kuomintang government commenced efforts to claim China’s maritime boundary limits.⁶ Yang Huairen, born in 1917, was a  Chinese geographer who was educated in Britain. The Nationalist government of China employed Yang to demarcate the Nanfang Hai (南方,  ‘Southern Sea’).⁷  In 1947, he worked on the available Chinese maps and etched a U-shaped figure to enclose that part of the sea which was later to be claimed by the Chinese government. The U-shaped figure was drawn not by a continuous line but a series of broken lines. This was argued as indicative of the then nationalist government’s understanding of its maritime interests and laws existing then. The broken lines indicated the Chinese Nationalist Government’s willingness to permit maritime activities like trade, commerce and fishing to other countries in the region while retaining its right for sovereignty and security of the area within the U-shaped figure.⁸ This U-shaped figure consisted of 11 broken lines (hence, 11-dash lines) and demarked around 90% of the South Sea. Further, Yang Huairen identified 286 bits of rock and turf within the U-shaped figure. He gave official name to each rock and reef, referring to the territory collectively as the “South China Sea Islands.”⁹ According to Wang Ying, a disciple of Yang  Huairen and a member of the prestigious Chinese Academy of Sciences, “All the lines have a scientific basis”. Wang also argues that “When we made the line, we stressed a humanitarian spirit. We allowed the neighbouring countries to pass through it without obstacles.”¹⁰ In 1949, the communists founded the People’s Republic of China and the nationalist Kuomintang forces fled to Taiwan. After coming to power, the new government inherited all the maritime claims in the South China Sea.

9-Dash line Claim. In 1952, Chairman Mao Zedong of China removed two hyphens (dashes) from the 11-Dash lines claim of the Chinese over the South China Sea. The two-dashes removed were that off the Gulf of Tonkin near Vietnam.¹¹ This was done by China to appease and lure the socialist  Vietnam and to keep them away from other external influences.¹² The Chinese have articulated this claim since then. In 2010, the Chinese declared that they viewed the South China Sea as a core interest at par with Taiwan and Tibet.¹³ Later, then US Gulf of Secretary of State Hillary Tonkin Clinton has disclosed that the Chinese had conveyed this during the 2 US-China nd Strategic and Economic Dialogue in Beijing held on 24 and 25 May 10.

Fig 1: The nine-dash line map which China attached its note verbal in 2009

10-Dash Line Claim. Recently, there are reports of China adding one more broken line (dash) to its 9-dash claim in the SCS. Chinese passports are inscribed with a map with nine dashes through the South China Sea and an additional 10 dash that th encompasses Taiwan.¹⁴ In 1949, when communists took over control in mainland China, the nationalists had retreated to Taiwan. China always claimed Taiwan as its territory. Presently, it has commenced including that based on a map by China’s Ministry of Natural Resources (2023) argument to its SCS claims and portraying it by including one more broken line to area off Taiwan in the SCS charts/ maps. This is also endorsed/ inscribed in Chinese passports, which is a rather unusual step for such documents.

Fig 2: The 2023 version of China’s ten-dash line claim in the South China Sea, including a new dash east of Taiwan. Source: Sankei Shimbun / JAPAN Forward, based on a map by China’s Ministry of Natural Resources (2023)

Relations and Disputes in SCS: Late 20^th and Early 21^st Centuries.  Disputes between China and other countries in the region are numerous and are beyond the scope of this paper. However, a broad analysis of all the disputes would be that all are about claims to sovereignty over waters and features in the region. This is mainly to progress resource exploitation and to quench nationalist expectations in respective countries. After the Second World War, as in other parts of the world, countries in and around SCS gained independence one by one from their colonial masters. In the SCS, the issue between the countries in the region was mainly focused on fishing till about the 1960s.¹⁵ With the likely finding of oil and natural gas the focus shifted to gaining the ownership of these resources by claiming the natural features in the region like islands, rocks and reefs. Each country in the region adopted measures to occupy these features with an aim to claim sovereignty or exclusivity for exploration of the newly found resources. The region witnessed several military conflicts/ skirmishes amongst the countries in the 1970s and 80s.¹⁶ China and Vietnam went to war in Jan 1974 over a dispute over Paracel islands. In 1982, the Third United Nations Convention on the Law of the Sea (UNCLOS) came into being. Now, countries commenced projecting their claims in accordance with the clauses of UNCLOS. Here, the disputing states began occupying islands to ensure physical presence and/ or tried to construct or create physical structures on the islands where occupation was unfeasible. In 1990, then Chinese Premier Li Peng, articulated the proposal of ‘Set Aside Dispute and Cooperative Exploration’.¹⁷ This resulted in reduction of military conflicts, but trust deficits continued to exist between the countries. The collapse of Soviet Union in 1991 forced Vietnam to normalise its relationship with China. However, uneasiness in China-Philippines relations increased. To counter China, Philippines signed Visiting Forces Agreement (VFA) with the United States in 1998.¹⁸ This period also saw ASEAN establishing itself 18 as an effective regional organisation with member countries coordinating their policies and responses to China collectively through ASEAN. In 2002, a ‘Code of Conduct on the South China Sea’ was signed by all the regional stakeholders who said that all the disputes between the countries regarding claims in the SCS are to be resolved mutually.¹⁹ The signing of this treaty heralded an era where cooperation was the order of the day and escalation of any differences and disputes were avoided. That, in any case was the theory; in practice, it is not quite so.

Claimants and Claims in SCS. China claims all the features within the 9Dash lines, and it occupies eight islets.²⁰ Vietnam occupies more than twenty islets or rocks; Taiwan one; the Philippines eight and Malaysia three to six.²¹ All claimants base their claims in modern international laws, while historical evidence is also used. The Chinese claim for Spratley and Paracel islands and 9-dash line claim is based on historical background. Chinese argue that these islands were discovered by them first and were a Chinese territory since 300 AD.²² Chinese Congress passed a law to claim the waters off these islands. Vietnam proved its effective and continuous control of the area in known recent times and bases its claim on the inheritance ground.²³ Malaysia’s claim is primarily on legal ground as Southern Spratley features, which it claims, is within Malaysia’s continental shelf.²⁴ Similarly, the Philippines bases its claim on the continental shelf. Indonesia limits its claim to the Exclusive Economic Zone and continental shelf. Brunei argues in accordance with UNCLOS for a straight-line projection of its EEZ.²⁵ Neither Indonesia nor Brunei claims the Spratly and the Paracel Islands.

Complaint by Philippines at PCA, Hague. Events that led to Philippines’ complaint against China at the Permanent Court of Arbitration (PCA), in The Hague under Annex VII to the UNCLOS are well known.²⁶  On 22 January 2013, Philippines served a notice to China on its unlawful activities in the South China Sea and filed a complaint with the International Tribunal for the Law of the Sea (ITLOS) at the Permanent Court of Arbitration (PCA), Hague under Annex VII to the UNCLOS.²⁷ The case is known as South China Sea Arbitration (PCA case number 2013–19). The complaint included 15 submissions. Philippines accused China of violating international maritime law in the SCS.²⁸

 PCA, Hague Verdict. The Permanent Court of Arbitration awarded the verdict on the Philippines submissions on 12 Jul 2016, declaring that there was “no legal basis” for the nine-dash line claim of China in the South China Sea. Further, it stated that the verdict was final and binding.²⁹

Reactions by China:

•  During the Tribunal Hearing. China did not agree to Philippines’s submissions to the PCA, Hague and stated that it was willing to discuss the issues bilaterally and resolve them with mutual consensus. As an official reply to Philippines submission of the South China Sea Arbitration on 19 Feb 2013, China stated its unwillingness to participate in the arbitration. On 01 Aug 2013, China indicated that "it  does not accept the arbitration initiated by the Philippines.”³⁰ In order to elaborate its position and due to growing nationalist sentiments, on 07 Dec 14, China published a white paper clearly announcing that it stands by the 9-dash lines claims in the SCS.
• Post PCA Verdict. China rejected the ruling of the PCA, Hague on the South China Sea Arbitration (PCA case number 2013–2019). However, the Chinese statement said that “all nations should respect international laws”.³¹ It exhorted that China will continue its efforts of resolving every dispute in the SCS through mutual, bilateral discussions with the countries involved. In Sep 2017, during a meeting with the US State Department officials, senior representatives from the Chinese Ministry of Foreign Affairs advanced a new legal theory on its claim over SCS.³² Instead of the ‘Nine-Dash Line’, officials argued for China’s sovereignty claims over the ‘Four Sha’ island groups in the South China Sea.

Four Sha Claim

Articulation of ‘Four Sha Claim’. The Chinese articulation of the new legal theory of ‘Four Sha’ claims over SCS was first reported in 2017 by Bill Gertz in the ‘The Washington Free Beacon’.³³ He said that during closed door meetings with the US State Department officials in Boston on 28 and 29 Aug 2017, the Deputy Director General Ma Xinmin of the China Foreign Ministry’s Department of Treaty and Law “asserted sovereignty and maritime entitlements extending from four island groups in the South China Sea – Dongsha, Xisha, Nansha and Zhongsha”. According to the report, these island groups collectively are referred to as the ‘Four Sha’ (四沙, sha meaning sand). These areas are respectively referred to as the Pratas Islands, Paracel Islands, Spratly Islands and the Macclesfield Bank area in English. The report stated that “Ma, the Foreign Ministry official, announced during the meetings that China is asserting sovereignty over the Four Sha China Sea, showing the transition from the Nine-Dash through several Line to the ‘Four Sha’ doctrine encompassing four legal claims”. He stated the area is China's historical territorial waters and also part of China's 200-mile Exclusive Economic Zone that defines adjacent zones as sovereign territory.

Fig 3: China’s evolving maritime claims in the South China Sea, showing the transition from the Nine-DashLine to the ‘Four Sha’ doctrine encompassing four

Origin of ‘Four Sha Claim’. The ‘Four Sha’ concept is not new to China’s claims in the South China Sea. It is understood that China has been working for a long time to put forth an alternate narrative to its much maligned ‘9Dash claim’ over the SCS. The constituent parts of China’s ‘Four Sha claim’ have long been set forth publicly in Chinese domestic law and official statements. China’s 1992 law on the territorial sea and contiguous zone, declared that China’s land territory included the “Dongsha island group, Xisha Island group, Zhongsha island group, [and] Nansha island group”.³⁴ In 1996, China declared straight baselines around the Paracel (Xisha) Islands, treating them as a single geographical unit. A 2016 white paper disputing the Philippines’ claims in the South China Sea arbitral process similarly claimed that China’s Nanhai Zhudao (the South China Sea Islands) consist of Dongsha Qundao (the Pratas Islands), Xisha Qundao(the Paracel Islands), Zhongsha Qundao (the Macclesfield Bank) and  Nansha Qundao (the Spratly Islands).³⁵ China may declare similar straight baselines around the Spratly (Nansha) Islands.³⁶ The Beacon report hints that China is preparing to declare straight baselines around all ‘Four Sha’ island groups.³⁷

Analysis: ‘Four Sha Claim’

‘Much more than Four Sha!’ China giving up almost 90% claim of South China Sea (Nine-Dash line claim) and proposing an alternate benign ‘Four Sha claim’ should surprise only the unwary and the unwatchful. This is because once the ‘Four Sha’ narrative catches on and becomes the new normal, China is likely to submit claims of ‘Territorial Sea’ and ‘Exclusive Economic Zones’ around each of these ‘Sha(s)’ along with the current claim of straight archipelagic baseline. This would eventually result in China claiming almost all of SCS! As such Chinese interpretation of UNCLOS includes a perception of sovereignty within the EEZ though it differs from accepted understanding of UNCLOS regulations by most other countries. With their current interpretation of UNCLOS, China could further challenge navigational freedom, aircraft operations etc., within the expanded EEZ she could gain once ‘Four Sha claim’ is accepted. Hence, China with its ‘Four Sha claim’ is not just aiming more maritime space in SCS. Its aim is a slow but steady unchallenged acceptance of ‘Chinese UNCLOS interpretation’ by its maritime neighbours initially and global acceptance subsequently!

‘Four Sha’ and Scarborough Shoal. The newly articulated ‘Four Sha’ claim of the Peoples Republic of China is prominent by its omission of the contentious Scarborough shoal. Scarborough Shoal, also known as Panatag Shoal located between the Macclesfield Bank and Luzon Island in the South China Sea. It was earlier administered by the Philippines. During the 2012 Scarborough Shoal standoff, China sent warships to this area and skirmishes occurred between the two countries. Subsequently, the administration of the shoal was taken over by the People’s Republic of China (PRC). The Philippines complaint at PCA, Hague included this issue and has been already mentioned the verdict was in their favour. China’s decision not to include Scarborough shoal in its claim could be seen as a considered and thoughtful decision. China, by this decision, is sending a message to the world of (partial!) abidance with the PCA verdict, while messaging to Philippines its desire to resolve the issue bilaterally. Simultaneously, by not mentioning Scarborough shoal, China is sending a loud message to its own nationals that the shoal is already a Chinese territory and is being administered by it and, hence, does not require any further formal declaration.

International Reaction to ‘Four Sha Claim’. China has not advertised or strongly broadcast its new argument of the ‘Four Sha claim’ in the SCS. Hence, international reactions have been muted and other than that by the United States and a few SCS watchers are hardly even whispered. The US State Department spokesman Justin Higgins said the department does not comment on diplomatic discussions.³⁹ However, he added that "The United States does take principled positions and has been clear and consistent, that maritime claims by all countries in the South China Sea and around the world must be made and pursued in accordance with the international law of the sea as reflected in the 1982 Law of the Sea Convention".⁴⁰ Meanwhile  maritime law experts who monitor issues in SCS view the ‘Four Sha claim’ of the Chinese with straight baselines around the islands group as contrary to the UNCLOS. Experts opine that Article 47 of the UNCLOS states that archipelagic baselines may only be drawn if they enclose a state’s “main islands and an area in which the ratio of the area of the water to the area of the land, including atolls, is between 1 to 1 and 9 to 1.” China is not constituted “wholly by one or more archipelagos” and total land mass proportion to the ‘Four Sha islands’ is beyond above specified ratio.⁴¹ Recently, Philippines voiced its apprehensions at various regional and international forums. For instance, during the Association of Southeast Asian Nations (ASEAN) -China negotiations held from 9 to 11 April 2025, it voiced its strong concerns about actions endangering its vessels and personnel, emphasising adherence to international law, including the 1982 UN Convention on the Law of the Sea (UNCLOS) and the 2016 arbitration ruling that invalidated China's claims.⁴²

Comparative Analysis. A comparative analysis of the aspects of ‘9-dash line claim’ and the new ‘Four Sha claim’ of China is tabulated below:

Conclusion

The ‘Four Sha’ claim by China over the sovereignty of islands in the South China Sea is surely not old wine in a new bottle. Having tested the waters with the nine-dash line claim and not compromising on its original stand is a measure of the resolve by China to retain the sovereignty over the SCS, which according to them belongs to China. With an assertive diplomatic policy coupled with economic might, China has been able to suppress or overcome resistance within the region. China considers this as an opportune moment to put forward its claims in what it sees as a more acceptable and ‘smarter’ way aligned with existing international law. It is certain that China had been working on the proposal for long and passed various national laws to satisfy nationalist feelings on the issue. Having introduced the ‘Four Sha claim’ and keeping it at a low threshold of publicity, China would have just won the first step. The low resistance to its new proposal would surely be encouraging to the Chinese. Slowly, but steadily, ‘Four Sha claim’ would become the new normal and the claimants in the South China Sea would be left with no option but to work around and within this concept to resolve their disputes. Hence, the ‘Four Sha’ claim is advantage China in the South China Sea for now. The question for all, including Indian policymakers to consider is “what should be done”?