The use of templates in China’s and the United States’ free trade agreements: a text-based analysis

States are known at times to employ a template, or boilerplate, when negotiating international agreements such as Free Trade Agreements (FTAs) and bilateral investment treaties. Two key reasons have been identified for doing so (Allee and Elsig Citation2019). For less developed countries, it minimises the burden on scarce bureaucratic resources, while for the most powerful states, it enables them to shape global regulatory systems in their own image and interests. This article utilises a text-as-data analysis (known as Jaccard Indexes) of 24 FTAs signed by the United States (US) and China, calculating measures of textual similarity between the legal texts. The article confirms that the US has used a boilerplate for its FTAs, albeit one that has varied by region, but that China shows greater willingness to have FTAs differ from country to country. The article thereby provides evidence to refute the claim seen in the existing literature that the most powerful states—as these two are—will adopt a boilerplate approach to their international agreements.