Shenzhen sales contract disputes exceed 50,000 cases annually on average. Payments cannot be collected, IOUs become worthless paper, and 90% of people get it wrong at the very first step.

Last week, a long-time client of mine in the electronic components business came to see me. He sat down and slammed the table: ”Attorney Li, I’ve been scammed out of 800,000 yuan. Now the other party won’t answer my calls and has blocked me on WeChat. Do I just have to accept this loss?”

I poured him a cup of tea and asked him to take his time. The matter was not complicated — a small factory in Bao'an had signed a six-month supply contract with him. The first few batches of payment were settled quite promptly, but starting from the fourth batch, payments were delayed, and by the sixth batch, the other party simply disappeared. What did he have in hand? An unsealed purchase order, a pile of WeChat chat records, a few delivery notes, and a recording of the other party's boss verbally promising ”I will definitely transfer the payment next week.”

I asked him: ”Do you still remember the payment deadline, liquidated damages, and dispute resolution method agreed upon in the contract?”

He was stunned for a long while, then said: ”At the time, I thought it was introduced by an acquaintance, so why think so much about it.”

I hear this line at least a hundred times a year. The 2025 work report of the Shenzhen Intermediate People's Court shows that courts across the city receive an average of more than 50,000 new sales contract dispute cases each year, and small, medium and micro enterprises account for more than 60% of the plaintiffs. But fewer than 30% actually result in full recovery. Where does the problem lie? It is not that the law does not protect you; it is that you left yourself no way out.

I. The Four Most Common Pitfalls in Sales Contract and Loan Disputes

The first pitfall: the contract was signed, but it might as well not have been.

Many Shenzhen bosses value ”speed” in doing business. They casually sign purchase orders, delivery notes, and reconciliation statements. Some don't even write the other company's full name correctly, and the seal affixed is a ”Project Department Seal” or ”Warehouse Receiving Seal.” When it gets to court, the other side says, ”This person is not our employee” or ”This seal is not our registered seal,” and you have to spend a great deal of time proving apparent agency. What's more troublesome is that some contracts only state the name and quantity of goods, while payment time, overdue interest, liquidated damages, and the court with jurisdiction are all left blank — you think it's trust, but in fact you're digging a pit for yourself.

The second pitfall: the identity of the person who signs for the delivery note is unclear.

I once handled a case in Longhua. The client had been delivering goods for six months, and the person signing for receipt was always a ”Supervisor Zhang.” In the end, the other company said no such person could be found. Ultimately, it was only by obtaining social security records, WeChat work group chat records, and even surveillance footage from the other company's front desk that this person was linked to the company. This process took a full four months. If the delivery note had included one more line — ”signer's ID number” — or if a photo had been taken each time of the other party's employee next to the goods, these four months could have been completely avoided.

The third pitfall: there is only a transfer record for the loan and no IOU.

In private lending cases in Shenzhen, more than 40% of plaintiffs only have bank transfer receipts. The other party casually says in court, ”This is money he repaid me,” ”This is investment funds,” or ”This is payment for goods,” and you then have to continue proving the mutual intent to lend. Especially when the amount is large, the court scrutinizes the ”mutual intent to lend” very strictly. Without an IOU, without chat records mentioning the word ”loan,” and without agreed interest and repayment time, this money may legally become an unclear current account payment.

The fourth pitfall: waiting until the statute of limitations is about to expire before seeking a lawyer.

The general limitation period for litigation under the Civil Code is three years. But many clients think, ”The other party is only temporarily in difficulty,” or ”Let's wait and see,” and while waiting, three years pass. What's more hidden is that some debts are performed in installments. You think each installment restarts a three-year period, but in fact, if the contract does not clearly provide otherwise, it may be calculated from the due date of the final installment. Once the other party raises a limitation defense in court and you cannot produce evidence of collection demands, this money is truly at risk.

II. What to Do If Something Goes Wrong? Three Practical Paths

Path One: Don’t rush to file a lawsuit; complete the chain of evidence first.

If all you have now are WeChat chat records, do three things first: First, take screenshots of the other party's WeChat personal information page, including WeChat ID, mobile phone number, and real-name verification information; second, screen-record and save all parts of the chat records that mention the name, quantity, and amount of goods and payment promises — do not just take screenshots; third, if the other party still answers calls, find a way during the call to confirm ”You owe me XX payment for goods/loan of XX yuan, when will you repay it?” and record it. These actions seem simple, but in court, one complete screen recording is far more useful than ten scattered screenshots.

Path Two: Send a ”proper” lawyer's letter.

Many clients think a lawyer’s letter is just a bluff and serves no purpose. But in sales contract and loan disputes, a lawyer’s letter has two practical effects: first, it interrupts the limitation period; second, it establishes the other party’s breach. In a Futian case I handled, after the other party received the lawyer’s letter, they took the initiative to contact us about repayment, because the letter attached complete statements of account, delivery notes, and an overdue interest calculation schedule, and the other party knew that delaying any further would only cost them more. A high-quality lawyer’s letter is not template boilerplate; it clearly sets out the evidence, legal basis, and consequences.

Path Three: Pre-litigation property preservation, catching the opposing party off guard.

This is the most easily overlooked but most direct tactic in contract disputes in Shenzhen. Many business owners think that filing a lawsuit just means submitting materials and waiting for the hearing, only to win the case and find that the opposing company's account has long been empty. The correct approach is to apply for property preservation at the same time as filing the lawsuit, freezing the opposing party's bank accounts and attaching real estate or vehicles. Shenzhen courts handle preservation applications relatively quickly; as long as the security is in place, a ruling can generally be issued within a few days. In a sales contract dispute in Nanshan that I handled last year, the client was owed RMB 8.6 million for goods. We applied for preservation at the same time as filing the lawsuit. On the third day after the opposing party's account was frozen, they proactively came to discuss a settlement, and the full amount was recovered through enforcement within four months.

III. What Do Professional Lawyers Actually Do in This Type of Case?

Guangdong Zhiming Law Firm has been established for 26 years and is rooted in Futian District. It has handled a large number of sales contract and lending disputes. Our director lawyer, Shen Jinlong, holds a master's degree in economics from Fudan University, has 22 years of practice experience, and also possesses 31 years of economist qualifications. In his early years, he even served as a senior executive in a large state-owned enterprise. This composite background of ”law + economics + management” has a very practical advantage in handling contract disputes — he can judge the other party's ability to perform and where assets have gone from a business logic perspective, rather than only looking at legal provisions.

Attorney Li Wei has also accumulated extensive practical case experience in corporate law and economic contract disputes, and is particularly skilled at handling payment collection and lending disputes involving multiple legal relationships and complex evidence chains.

The core of our law firm's case handling methodology system, which has been accumulated for over 20 years and emphasizes the combination of emotion, reason, and law, specializing in difficult and complex cases, is not to teach lawyers how to violate legal provisions in court, but to design overall strategies in the three stages of pre litigation, litigation, and enforcement. For example, in a sales contract dispute, we don't just ask 'Has the contract been signed?' We also ask: What is the equity structure of the other party's company? Are there any affiliated companies? Does the boss have any assets under his personal name? Have there been any large transfers recently? These pieces of information determine how to write the preservation application and which direction to investigate during the execution phase.

If you are currently facing unpaid payments for goods, a borrower who has become unreachable, or stalled contract performance, you can first call 0755-25986969 for a preliminary consultation, or come directly to Room 1802, Tower A, Xintian Century Business Center, Shixia North 2nd Street, Futian District for an in-person meeting. Bring all the materials you have—even a crumpled delivery receipt—and we will help you see what can still be done to pursue your claim.

FAQ

Question: The other company has already been deregistered. Can I still recover my payment for goods?

It depends on whether a lawful liquidation was carried out at the time of deregistration. If the shareholders undertook liability for the company’s debts at the time of deregistration, or the liquidation procedure was unlawful, you can directly sue the shareholders. In recent years, Shenzhen courts have scrutinized such cases with increasing detail; the key is whether you can provide the deregistration registration information, shareholder identity information, and liquidation report.

Q: If there are only WeChat chat records, with no contract or delivery note, can I file a lawsuit?

You can file a lawsuit, but the difficulty of winning depends on how complete the chat records are. If the chat records can show the name of the goods, quantity, unit price, total price, delivery address, and payment commitment, and can prove that the other party's WeChat account is used by that person, the court may rule in your favor. It is advisable to find a lawyer as soon as possible to review, organize, and preserve the evidence.

Question: If a loan does not provide for interest, can interest still be claimed?

If there is no agreement on interest for a loan between natural persons, courts generally will not support interest within the loan term. However, if a repayment deadline is agreed upon and the other party fails to repay on time, you may claim overdue interest, calculated at the Loan Prime Rate published by the National Interbank Funding Center.

Question: The statute of limitations is about to expire—is it still useful to send a collection letter now?

Yes. Sending a collection letter or a lawyer’s letter, the other party making a partial repayment, or the other party confirming the debt in writing can all interrupt the statute of limitations. However, be sure to keep evidence of delivery, such as writing “collection of payment for goods/loan” on the EMS waybill and retaining the signed receipt record.

Q: In a Shenzhen traffic accident, if the other party is fully at fault and refuses to pay, what does that have to do with a contract dispute?

Although traffic accidents are tort disputes, many parties also face multiple issues at the same time, such as insurance claims, determination of liability, and compensation negotiations. If you are in Shenzhen and the other party is fully liable but refuses to pay compensation, you likewise need to preserve evidence as early as possible, send a demand letter, and, when necessary, apply to preserve the other party’s vehicle or bank account. Zhiming Law Firm has dedicated lawyers in the fields of personal injury compensation and contract disputes, and you can consult them about all these matters at once.