Adopted: June 26, 2026

Effective Date: January 1, 2027

1.Main Procedural Amendments

1.1 Opposition Period Shortened to 2 Months

Statutory Provision: Article 36

Old Rule: A 3‑month opposition period is granted from the publication date of a preliminarily approved trademark.

New Rule: The statutory opposition period is shortened to 2 months.

Practical Impact for Foreign Clients

Foreign applicants shall upgrade watch service for the shortened 2‑month opposition term, optimize trademark‑monitoring workflows and shorten response timelines. All procedural steps, such as evidence gathering, internal corporate approvals, document translation and issuing legal instructions to Chinese legal counsel, must be completed sufficiently in advance of the statutory deadline. Although evidences can be supplementary filed within 3 months since the initial filing, last‑minute opposition filings without any evidences may be rejected by the Office.

1.2 Ex‑Officio Cancellation for Non‑Use or Genericized Trademarks

Old Rule: Trademark cancellation based on three‑year non‑use or genericisation could only be initiated by third‑party applicants; CNIPA had no authority to cancel registered trademarks on its own initiative.

New Rule: CNIPA may initiate ex-officio cancellation based on non-use for consecutive 3 years or genericized trademarks.

Statutory Provision: Article 57 Paragraph 3

Practical Impact for Foreign Clients

Foreign right‑holders shall refrain from registering large‑scale dormant defensive trademarks without legitimate business purposes. Systematic long‑term retention of evidence for genuine trademark use (including online commercial use) in the Chinese market is essential to avert ex‑officio cancellation risks initiated by CNIPA.