Truck USD 252 billion Rail USD77 billion FTZ USD 83 billion Other USD 37 billion Source: Import Trade Trends: FY 2004 Year End Report (October 2003-September 2004), US Department of Homeland Security, January 2005, p. 25(available http://www.customs.ustreas.gov/linkhandler/cgov/toolbox/about/accomplish/ trade trends fy04. ctt/trade trends fy04. pdf) In China, total container trade rose to 65 million TEUs(twenty-foot equivalent units) in 2003 with more than two-thirds being handled in mainland China ports. [4]The container volume exported is expected to reach 100 million TEUs by 2010, according to Zhang Chunxian, China's Minister of Communications, speaking at the New York-New Jersey Port Industry conference Zhang also predicted that total trade of tonnage will jump from I billion tons 2004 to 3.5 billion tons by 2010.5] The tremendous volume of shipping activities taking place in the US and in China makes the two countries popular forums for ship arrest proceedings In this article it is argued that ship arrest law is a part of maritime law and that the historical development of a country's maritime courts has a strong bearing on its approaches to rules of interpretation and construction. Hence, first a historical analysis of the maritime court systems of the two countries will be presented. Secondly, it is argued that a country' s admiralty jurisdiction will have a strong correlation with its national policy on maritime development the context in which its ship arrest law operates. Thus, the different approaches taken by the US and China to promote a uniform system of maritime law will be examined. Thirdly, the scope of ship arrest is Died by analyzing its definition. China has been shifting away from the absolute immunity doctrine that most socialist countries still insist on. The section examining the conflicts of law relating to ship arrest contains a comparative analysis of the different approaches the US and China take in using the law of the flag as a solution. Using the law of the flag as a solution allows maritime creditors to know in advance which order of priorities applies to their maritime liens. In this section, a description will be given of the current developments in the different ways in which the two countries take on such practices. After a comparison of the Chinese and US approaches to maritime liens and their ranking with mortgage, the Chinese and US approaches to in personam and in rem actions are examined. Next, the different approaches adopted by the two countries to extending ship arrest power to new rights are explored, namely the container leasers'right to arrestTruck USD 252 billion Rail USD77 billion FTZ USD 83 billion Other USD 37 billion Source: Import Trade Trends: FY 2004 Year End Report (October 2003 – September 2004), US Department of Homeland Security, January 2005, p. 25 (available at http://www.customs.ustreas.gov/linkhandler/cgov/toolbox/about/accomplish/ trade_trends_fy04.ctt/trade_trends_fy04.pdf). In China, total container trade rose to 65 million TEUs (twenty-foot equivalent units) in 2003, with more than two-thirds being handled in mainland China ports.[4] The container volume exported is expected to reach 100 million TEUs by 2010, according to Zhang Chunxian, China’s Minister of Communications, speaking at the New York–New Jersey Port Industry conference. Zhang also predicted that total ocean trade in terms of tonnage will jump from 1 billion tons in 2004 to 3.5 billion tons by 2010.[5] The tremendous volume of shipping activities taking place in the US and in China makes the two countries popular forums for ship arrest proceedings. In this article it is argued that ship arrest law is a part of maritime law and that the historical development of a country’s maritime courts has a strong bearing on its approaches to rules of interpretation and construction. Hence, first a historical analysis of the maritime court systems of the two countries will be presented. Secondly, it is argued that a country’s admiralty jurisdiction will have a strong correlation with its national policy on maritime development, the context in which its ship arrest law operates. Thus, the different approaches taken by the US and China to promote a uniform system of maritime law will be examined. Thirdly, the scope of ship arrest is studied by analyzing its definition. China has been shifting away from the absolute immunity doctrine that most socialist countries still insist on. The section examining the conflicts of law relating to ship arrest contains a comparative analysis of the different approaches the US and China take in using the law of the flag as a solution. Using the law of the flag as a solution allows maritime creditors to know in advance which order of priorities applies to their maritime liens. In this section, a description will be given of the current developments in the different ways in which the two countries take on such practices. After a comparison of the Chinese and US approaches to maritime liens and their ranking with mortgage, the Chinese and US approaches to in personam and in rem actions are examined. Next, the different approaches adopted by the two countries to extending ship arrest power to new rights are explored, namely the container leasers’ right to arrest