The People’s Republic of China can be described as the largest business partner of the Russian Federation, and the issue of choosing the law applicable to contracts with a foreign element is not only relevant in the era of economic integration but is still debated in the scientific community. The aim of the article is to compare the approaches of the legislators of both countries to the issue of conflicts that arise in private international law due to different organization of the legal systems of countries participating in international commercial relations. As a result, the same legal facts are interpreted differently by national legislation, which leads to numerous disputes and often infringe interests of one of the parties. The subject of the research is the legislation regulating private international law sector of Russia and China; Russian and Chinese approaches to the legal consolidation of collision principles; features of the application of the principle of autonomy of the will of the parties, the written and implied forms of agreements on applicable law, as well as agreements on applicable law that require interpretation. In the article is used an analysis of legal acts and a formal legal method, which includes a description of the rules of law and the establishment of legal features of the phenomena under consideration. The theoretical significance of the work is due to the formulated conclusions, in which the similarities and differences in the legislative regulation of the agreements of the parties on the applicable law are revealed.