As a geographical concept, Greater China consists of mainland China, Taiwan, Hong Kong, and Macau. Mainland China has been under the rule of the Chinese Communist Party (CCP) since 1949 and is internationally known as the People’s Republic of China (PRC). Taiwan, or the Republic of China, is a separate political entity under the rule of the Nationalist Party, whose leaders fled to the island when the CCP took over mainland China. Taiwan has become a free and democratic society since the early 1990s. Hong Kong, an international metropolis bordering the southern tip of mainland China, was returned to the PRC in 1997 after having been a British colony for more than a century. Macau, a small enclave neighbouring Hong Kong, was returned to the PRC in 1999 after having been a Portuguese colony for more than three centuries.

In the early 1980s, several CCP leaders came up with the idea of ‘One Country Two Systems’, hoping that people in Taiwan, Hong Kong, and Macau would agree to be united with mainland China. ‘One Country’ indicates there will only be one China, namely the PRC, with all four entities merged. ‘Two Systems’ promises that Taiwan, Hong Kong, and Macau, upon their union with mainland China, will continue to practise capitalism and their existing political, economic and legal systems, and ways of life will remain largely intact for at least 50 years. The fact that the independence of Hong Kong’s legal system was guaranteed after the 1997 handover accounts for the different ways in which pornography is regulated in the two jurisdictions, as outlined below.