China’s Revised Trademark Law (2026): What Trademark Owners Need to Know Before January 1, 2027
China has enacted its most significant trademark reform in over 40 years. The revised Trademark Law of the People’s Republic of China, adopted on June 26, 2026 by the Standing Committee of the National People’s Congress, will take effect on January 1, 2027.
This overhaul modernizes China’s trademark system strengthening registration standards, curbing bad‑faith filings, enhancing enforcement, and tightening administrative oversight. For businesses that own or plan to register trademarks in China, the new law introduces important compliance obligations that should be addressed before 2027.
Why Was China's Trademark Law Revised?
The 2026 revision is the first comprehensive update since the original Trademark Law was enacted in 1983. It expands the law to 87 articles across nine chapters, targeting longstanding system weaknesses and aligning with global best practices.
Key policy goals include:
- Improving the trademark registration and examination system.
- Preventing bad‑faith and excessive trademark filings (e.g., hoarding, squatting).
- Strengthening trademark administration and CNIPA oversight.
- Enhancing protection of exclusive trademark rights.
- Encouraging genuine use of registered trademarks.
- Improving enforcement against misleading or infringing practices.
A Critical Compliance Priority: Accurate Owner Information
One of the most practical—but easily overlooked—changes is the heightened emphasis on keeping trademark owner records up to date with the China National Intellectual Property Administration (CNIPA).english.cnipa.gov+1
Under the revised law, trademark owners must ensure that the registered name and address on file with CNIPA accurately reflect their current legal identity. If either changes after registration (e.g., due to a corporate reorganization, merger, name change, or office relocation), a recordal of change must be filed.natlawreview+1
Failing to update this information can lead to administrative complications, including difficulties in enforcement, renewals, licensing, assignments, and other trademark transactions.
Key policy goals include:
- Improving the trademark registration and examination system.
- Preventing bad‑faith and excessive trademark filings (e.g., hoarding, squatting).
- Strengthening trademark administration and CNIPA oversight.
- Enhancing protection of exclusive trademark rights.
- Encouraging genuine use of registered trademarks.
- Improving enforcement against misleading or infringing practices.
Can incorrect or outdated information lead to penalties?
Yes. The revised law strengthens administrative oversight.
Where a trademark owner’s name or address changes but is not updated, authorities may:
- Issue a correction notice requiring rectification within a specified period.
- Impose administrative penalties if the issue is not resolved in time.
Depending on the circumstances and applicable implementing regulations, penalties may include fines or, in serious or repeated cases, potential revocation of the trademark registration
Note on fines: Some industry alerts cite fines around RMB 50,000–55,000 (roughly USD 7,000–7,500). However, penalty amounts will depend on the exact legal provisions, implementing rules, and case facts. Businesses should rely on official CNIPA guidance rather than unofficial summaries.
Why This Matters for International Businesses
Many foreign companies registered trademarks in China years ago and may not have updated their records since. Common scenarios include:
- Company name changes
- Registered office relocations
- Corporate restructurings or mergers
- Changes in legal entity or holding structure
If these changes were never recorded with CNIPA, the trademark records may no longer match the company’s current legal identity creating compliance risk under the new law.
What Should Trademark Owners Do Now?
Before January 1, 2027, trademark owners should:
- Review Your China Trademark Portfolio
Check every registered trademark to confirm:
- Registered owner name
- Registered address
- Legal entity details
- Compare with Current Corporate Records
Verify that CNIPA records match your current business registration documents, certificates of incorporation, and other official records.
- FileRecordalsof Change Where Needed
If there has been any change to:
- Company name
- Registered address
- Corporate ownership (where applicable)
→ File the appropriate recordal of change with CNIPA as soon as possible.
- MaintainAccurate Trademark Records Forward
Up‑to‑date records reduce administrative risk and support smoother enforcement, renewals, licensing, assignments, oppositions, and invalidations.
Other Key Changes in the 2026 Trademark Law
Beyond owner information, the revised law introduces several substantive reforms:
Stronger Measures Against Bad-Faith Filings
Applications filed without intent to use or far beyond normal business needs may be refused. This targets trademark hoarding, squatting, and other malicious filing practices.
Improved Trademark Administration
The law streamlines registration, examination, and validation procedures while strengthening overall trademark management and CNIPA’s administrative role.
Enhanced Protection of Trademark Rights
The amendments reinforce enforcement against misleading use and improve remedies for legitimate trademark owners, including clearer pathways for administrative and judicial action.
Continued Focus on Genuine Use
The law retains (and in practice reinforces) the principle that trademarks unused for three consecutive years without legitimate reason may be subject to cancellation for non‑use.
Additional Notable Reforms (per leading IP firms)
Analyses from major IP practices highlight other changes of practical significance, including:
- Stricter regulation of trademark agencies.
- Updated rules on online trademark use and e‑commerce.
- Refined standards for well‑known mark protection.
- Tighter controls on assignment and licensing practices.
How LogicizeIP Can Help
If your business owns trademarks in China, now is the right time to conduct a pre‑2027 compliance review. LogicizeIP can assist you with:
- Portfolio audit: Reviewing all your China trademark registrations.
- Data verification: Checking owner name, address, and legal entity details against current corporate records.
- Gap identification: Flagging discrepancies between your internal records and CNIPA data.
- Recordals of change: Preparing and filing necessary updates with CNIPA.
- Ongoing portfolio management: Supporting renewals, assignments, licensing, and enforcement strategy in line with the new law.
