Written by Jennifer Eagleton.

The concept of “One Country, Two Systems” (一國兩制) was originally devised with Taiwan in mind and was subsequently repurposed for Hong Kong, so that Hong Kong could maintain its capitalist system while the socialist system remained unchanged in mainland China. However, as a rhetorical and legal strategy to “maintain the metaphorical and constitutional distance between China and Hong Kong” (Fu et al. 2007), and to “assert sovereignty and achieve unity” (Wesley-Smith 1996) it is somewhat contradictory. And as recent events in Hong Kong have shown, the principle, as a governance framework reflects its tri-fold ambiguity – an ambiguity that is rhetorical, ideological, and strategic. First, it was strategic as it allowed “contradictions” between the two places to exist in one country and also allowed Britain to withdraw with honour. Written as general principles into the Sino-British Joint declaration, the emphasis was on “Hong Kong people ruling Hong Kong” and with a “high degree of autonomy” apart from foreign affairs and defence. Maintenance of its systems including the legal system was also promised.

Second, the ambiguity is ideological as there was no precedent for two systems co-existing in the one country; it was written into China’s constitution that special administrative regions “could be established when necessary”.The “One Country, Two Systems” can be attributed to the Marxist-Leninist dogma of “dialectical and historical materialism” (Stalin 1938) as well as “seeking truth from facts” (that is, materialism) and the Marxist principle of the “unity of opposites” (or contradictions/dialectics). Deng Xiaoping had said: “Marxism is not a dogma but a guide to action» and that the dialectic is “evolutionary not mandatory” (2004).Within the dialectic of the “unity of opposites”, the political liaison between Hong Kong and Beijing is dynamic but not equal. The centre manipulates the “actual situation” of the periphery in perpetual tension, thus Deng’s saying of “crossing the river by feeling the stones”.

Thus, the principles underlying the concept of “One Country, Two Systems” could be subject to constant change (in the light of actual conditions on the ground). And since it was constantly reiterated that the “One Country” was the premise for the “Two Systems”, there is an implication that the “One Country” could take precedence over the “Two Systems”. As one pro-Beijing Hong Kong newspaper put it, “One Country, Two Systems” is a complete concept; it cannot be separated, you cannot only stress one aspect and ignore the other side”.

Last, the ambiguity is rhetorical, which relates to the undefined promise of elections (in the Sino-British Declaration) and universal suffrage (in the Basic Law). This is also a part of the overall strategic ambiguity and used to build up confidence that Hong Kong would continue on in similar ways to before. Neither of these terms was defined in either of these two documents. Although in “East meets west” Hong Kong, the meaning of “elections” would have a European slant, but in China elections are really “selections” out of a group of people deemed satisfactory. The Chinese constitution states that “The National People’s Congress and the local people’s congresses at different levels are instituted through democratic election, really democratic centralism. We run into the problem of different definitions of the one concept – and democracy being an “essentially contested concept”, means that there is no one definition acceptable to all.

In 1989, Jiang Zemin famously quoted a literary saying, “Well water [Hong Kong] does not mix with river water [the Mainland]” (井水不犯河水) to explain that Hong Kong should not interfere in China and that China would also not interfere in Hong Kong. It is perhaps this metaphor that encapsulates the ambiguity contained in the concept of “One Country, Two Systems”. Permutations of this and other “water” metaphors have occurred throughout the lifespan of the Special Economic Region, and illustrate the changing nature of the concept.  The massive protests of 2003 in connection to an anti-subversion bill (Article 23) let to increasing oversight of Hong Kong by Beijing officials.

The following are some instances of the “mixing of the waters” metaphor that occurred near some specific incidents over the last decade. They come from mostly from pro-democracy newspapers.

2004 April – China rules that its approval must be sought before any changes to Hong Kong’s election laws could be made, giving Beijing the veto any moves towards more democracy, such as direct elections for the SAR’s chief executive.

In regards to the current relationship between China and Hong Kong, “well water not interfering river water” has indeed been achieved. But river water is often interfering with well water and it sometimes even overflows the embankment and floods the tiny well of Hong Kong.  ( Apple Daily, 21 September)

 2005 December – Pro-democracy legislators reject Mr Tsang’s plans for limited constitutional reforms, saying they do not go far enough. Mr Tsang said these plans, which were very minor in nature, went as far as Beijing would allow.  From time to time some thought that the “second system” could affect the development of democracy in the Mainland.

..the truly important constitutional reform in China, leading her toward democratic rule of law; since river water is interfering with well water, instead of wishfully thinking of increasing the height of embankment to protect the well water, why not sneak into the rear area alone and plant tree in the source of river water? (Ming Pao Daily, 13 November)

2006 July – The annual 1st July march for democracy has always been a time of reassessment of the “One Country, Two Systems”.

After the July First protest in 2003, there was a growing tension in the “two systems in politics”. The “patriotism” theory and dual universal suffrage controversy in 2007/08 symbolize that “two systems in politics” may only be a very fragile and blurry curtain. Under the mutual suspicion of intervention vs. penetration (subversion), “Two systems” becomes a corset. Hong Kong’s current contribution and impact on China’s development is still being interpreted within the confines of the pan-economy. ( Ming Pao Daily, 1 July 2006)

 One essence of the “One country, Two Systems” is “river water not interfering with well water”…. [And] mainly and precisely refers to the social and political systems. In the economic, cultural and livelihood perspectives, “two systems” is not some insurmountable “moat”, but ensures mutual contact, complementary in advantages and common development.  (Ta Kung Pao, 15 July)

2007 December – Beijing says it would allow the people of Hong Kong to directly elect their own Chief Executive in 2017 and the Legislative Council by 2020. Chief Executive Donald Tsang hailed this as “a timetable” for universal suffrage, but pro-democracy campaigners expressed disappointment at the delayed date as they were hoping Beijing would say 2012.

2008September – Hong Kong’s pro-democracy camp wins over a third of seats in legislative elections, retaining a key veto over future bills.

 Democrats do not they start to finish in a position to engage in Hong Kong alone engage in subversion say it? As for well water, when will it flood over? ….This is the reason why Tung Chee-hwa told Szeto Wah not to not to engage in the June 4th gathering. (Ming Pao Daily, 6 January)

2009 December – Hong Kong authorities unveil proposals for political reform in response to pressure for greater democracy, including an enlarged Legislative Council; critics say the moves do not go far enough.

2010 May – Five opposition MPs are returned to their seats, in by-elections they triggered by quitting – a move intended to pressure China to grant the territory universal suffrage. The Democratic Party, whose symbol is a white dove, traditionally hostile to Beijing, holds its first talks with a Chinese official since the 1997 handover; some started to call them the “black dove” party.

 Maybe you say that I am an alarmist. Yes ah, the Mainland is the Mainland and Hong Kong is Hong Kong and, river water doesn’t mix with well water, what are we afraid of? But do you really do not feel a thing, one country…we settle down into the well water, but the river water tastes more concentrated ….… (Apple Daily, 13 May)

2011 January- Rao Geping, when talking with Wang Guanghua, head of Hong Kong and Macao Affairs of the State Council about the two judicial systems gave his views on the expression, “well water not mixing with river water”; he said that it was only a kind of metaphor and it is not able to express exactly the relationship between the two judicial systems under the “One Country, Two Systems”. In his view, the two places have independent judiciaries, but they also have something in common: “both the well water and river water is China’s water, and well water and river water are likely linked.”  (Ta Kung Pao, 14 January)

 2012 – The plan to introduce national education, which was widely criticized throughout the year as an attempt to brainwash pupils, was shelved in October after weeks of protests by thousands of residents outside the government headquarters in Admiralty. 

The Civic Party has an ulterior motive in “opposing National Education”, it is in fact that they do not want to identify with their country; they “oppose a Communist takeover”, which is blatantly against the central government, and they refuse to accept the legal rule of the People’s Republic of China. By this, the Civic Party is clearly overstepped the boundary of the well water mixing with river water, and this is extremely dangerous to the edge of Hong Kong. (Ta Kung Pao, 25 August)

2014 June – More than 90% of the nearly 800,000 people taking part in an unofficial referendum vote in favour of giving the public a say in short-listing candidates for future elections of the territory’s chief executive. Beijing condemns the vote as illegal.

 …..The small river has dried up, even the well has dried up, so where’s the water in the big river? There is no one specific and concrete home, never mind what country? Hong Kong’s local democratic movement is to protect the members of the family and to defend Hong Kong’s core values, fulfill the Basic Law, to select the right person according to the International Covenant on Civil and Political Rights. (Apple Daily, 25 March)

2014 August – Hong Kong government releases a white paper after a consultation period on political reform. However, the Chinese government rules out a fully democratic election for Hong Kong leader in 2017, and imposing even tight rules on nominations of candidates who want to run in the poll then the current system.

We are committed to the Basic law, is One Country, Two Systems, Hong Kong people ruling Hong Kong, and a high degree of autonomy. But today, 25 years later, the river water interferes again with well water again; last week’s “White Paper” claim that Hong Kong is very much like one country’s control, Beijing people ruling Hong Kong and with a low degree of autonomy, poor Hong Kong! (Ming Pao Daily 26 June)

There was no conflict between the two systems the two propositions eternal doctrine. Over ten years ago it was said that well water would not interfere with river water; now with the White Paper, there is a new interpretation of the existing two systems. (Ming Pao, 29 August)

2014 September-November – Pro-democracy demonstrators occupy the city centre and other sites for several weeks in protest at the Chinese government’s decision to limit voters’ choices in the 2017 election for the Chief Executive.

Dr Jennifer Eagleton is an adviser to the University of Hong Kong’s “Designing Democracy Hong Kong” project. Her PhD analysed how Hong Kong talks about democracy. Image Credit: CC by Pranav Bhatt/Flickr.


Deng, X. 2004. Deng Xiaoping on “One Country, Two Systems”. Hong Kong: Joint Publishing.

Fu et al., eds. 2007. Interpreting Hong Kong’s Basic Law: The Struggle for Coherence. New York: Palgrave Macmillan.

Stalin, J. 1938. “Dialectical and Historical Materialism”. This can be found at: http://www.marxists.org/reference/archive/stalin/works/1938/09.htm.

Wesley-Smith, P. 1996. “Law in Hong Kong and China: The Meshing of Systems.” Annals of the American Academy of Political and Social Science. 547: 104-117.

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