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            Congressional Research Service
            Informing  th Ieg satrve debate    o e 1914



China Primer: South China Sea Disputes


Overview
Multiple Asian governments assert sovereignty over rocks,
reefs, and other geographic features in the heavily
trafficked South China Sea (SCS), with the People's
Republic of China (PRC or China) arguably making the
most assertive claims. The United States makes no
territorial claim in the SCS and takes no position on
sovereignty over any of the geographic features in the SCS,
but U.S. officials have long urged that disputes be settled
without coercion and on the basis of international law.
Separate from the sovereignty disputes, the governments of
the United States, China, and other countries disagree over
what rights international law grants foreign militaries to fly,
sail, and operate in a country's territorial sea or exclusive
economic  zone (EEZ). Since the 113th Congress, some
Members  have examined  China's efforts to use coercion
and intimidation to increase its influence in the SCS and
have passed legislation aimed at improving the ability of
the United States and its partners to protect their interests.

An estimated one-fifth to one-third of global ship-borne
commerce  transits the SCS each year, including energy
supplies to U.S. allies and partners like Japan, South Korea,
and Taiwan. According to estimates cited by the U.S.
Energy Information Administration, the SCS contains
proved or probable reserves of approximately 3.6
billion barrels of oil and 40.3 trillion cubic feet of natural
gas. The SCS also contains significant fish stocks, coral,
and other undersea resources.

   isputes  over   Soveregnty
PRC  officials assert indisputable sovereignty over these
islands [of the SCS] and their adjacent waters without
defining adjacent waters. The PRC government depicts
its claims with a dashed line (see Figure 1) that
encompasses  approximately 62% of the SCS, according to
the U.S. Department of State. The PRC has never explained
definitively what the dashed line signifies.

In the northern part of the SCS, the PRC, Taiwan, and
Vietnam contest sovereignty of the Paracel Islands; the
PRC  has occupied them since 1974. The PRC and Taiwan
also claim Pratas Island, which Taiwan controls. In the
southern part of the sea, the PRC, Taiwan, and Vietnam
each claim all of the approximately 200 Spratly Islands,
while Brunei, Malaysia, and the Philippines, a U.S. treaty
ally, claim some of them. Vietnam occupies the most land
features in the island chain; Taiwan occupies the largest. In
the eastern part of the sea, the PRC, Taiwan, and the
Philippines claim Scarborough Shoal; the PRC has
controlled it since 2012. PRC and Taiwanese claims
overlap with the theoretical 200-nautical-mile (nm) EEZs
that five Southeast Asian countries-Brunei, Indonesia,
Malaysia, the Philippines, and Vietnam-could claim from


Updated December  22, 2025


their mainland under the 1994 United Nations Convention
on the Law of the Sea (UNCLOS).


Figure I. The South  China Sea


China's cdashed line
Island and shoal representations (enlarged for visibility).


Source: CRS. Boundaries from U.S. Department of State.

Isute over Freedom             ofthe Seas
A dispute over how to interpret UNCLOS underlies U.S.-
China tensions over U.S. military operations in and over the
SCS  and other waters off China's coast. The United States
and most other countries interpret UNCLOS as giving
coastal states the right to regulate economic activities
within their EEZs, but not the right to regulate navigation
and overflight through the EEZ, including by military ships
and aircraft. China, Vietnam, and some other countries hold
the minority view that UNCLOS  allows them to regulate
both economic activity and foreign militaries' navigation
and overflight in their EEZs.

The U.S. Navy routinely operates in the SCS and the
Taiwan  Strait, including transits of the Taiwan Strait and
Freedom  of Navigation Operations (FONOPs) near Spratly
and Paracel Islands to challenge maritime claims that the
United States considers to be excessive. U.S. Air Force and
Navy  aircraft fly surveillance and reconnaissance missions
in international airspace above the waters of the SCS,
including airspace that is close to (but outside of) China's
airspace. China regularly conducts military activities in the
SCS  and objects to U.S. military activities there. PRC
officials often say that U.S. military operations in the SCS
undermine regional stability. Other countries-including
Japan, Australia, Canada, the United Kingdom, and India-
also have operated naval vessels and aircraft in the SCS to
promote a free and open Indo-Pacific.