Abstract Background Drug use and in particular injecting drug use has been at the forefront of the explosive spread of HIV in general populations in many countries in Asia. There is concern that also in China increased HIV incidence in drug users might spark off a generalized epidemic in the wider population. Close monitoring of HIV incidence and risk factors in drug users is therefore important to be able to target interventions effectively. Second generation surveillance was launched to assess HIV prevalence and risk behaviours jointly with the purpose of describing trends and predicting future developments. To assess whether these goals were fulfilled among drug users in China we provide an analysis of risk factors for HIV infection and of regional differences in HIV prevalence. Methods We analysed data collected in 2005 in 21 drug user second generation surveillance sentinel sites from 14 provinces in China. We used random effects logistic regression to test for risk factors for HIV infection and regional differences. Results The overall HIV-1 antibody prevalence was 5.4% (279/5128); 4.9% among injecting drug users (IDU) not sharing needles and 3.7% among non-injecting drug users. We found substantial heterogeneity among the surveillance sites with prevalence rates ranging between 0% and 54%. HIV status was strongly affected by the regional prevalence of HIV. Risk behaviours were highly prevalent in regions where HIV prevalence is still low. The distribution of duration of drug use in different sites indicated different stages of the drug use epidemics. Conclusion ]Regional differences in HIV prevalence in China reflect different stages of the drug use and HIV epidemics rather than differences in risk behaviours. Therefore, outbreaks of HIV among drug users in regions where prevalence is still low can be expected in the future. However, methodological limitations of surveillance embedded into routine systems limit the usability of existing data. More standardized approaches to data collection in secondary generation HIV surveillance are necessary to better understand regional differences in risk behaviour and prevalence and to design targeted intervention for those regions at risk of experiencing outbreaks.