CHINA was not named in Hong Kong's paper on piracy submitted to the International Maritime Organisation (IMO).
But the paper calls for action to find out how much Chinese officials are involved.
It admits that when ships are boarded by ''uniformed persons'' it causes difficulties as to what action to take.
Incidents around Hong Kong waters reached a peak in April last year, but then fell significantly. There have been eight reports of piracy this year.
The Hong Kong paper says firearms, including automatic weapons and rockets, were used in 32 out of 100 incidents.
It adds: ''The reported manoeuvring of small boats operating in darkness and showing no navigation lights while sailing close to merchant ships in attempting to compel them to stop appears to have endangered the safety of ships and lives.'' In one case a crew was reported to have been locked up while boarders took charge of the ship and sailed it to another destination.