建造中的船舶抵押权,已成为国际普遍使用的船舶建造融资方式。实践中以建造中船舶作抵押担保,向银行借款融通资金的模式很多具有涉外因素,但我国没有相应的建造中船舶抵押权效力的法律冲突适用规则,不利于争议解决。本文主要通过阐述建造中船舶抵押权相关概念,分析各国对该抵押权效力法律冲突的法律适用,对完善我国的相关法律规定提出建议。 The mortgage of the ship under construction has become a commonly used method of financing shipbuilding in the world. In practice, there are many foreign-related factors, such as the construction of medium-sized ships as mortgage guarantee and the borrowing of funds from banks, but there is no corresponding applicable law for conflict of laws in the construction of the ship mortgage right in China, which is not conducive to dispute resolution. This paper mainly expounds the related concepts of mortgage in construction, analyzes the applicable law of each country to the legal conflict of the effectiveness of the mortgage, and puts forward suggestions on how to perfect the relevant laws and regulations of our country.