China’s trademark system has undergone significant transformation over the past several years. Applications have declined somewhat, but approval rates have improved. Overall enforcement has also improved, becoming more evidence driven; authorities are increasingly focused on curbing bad-faith filings and raising the overall quality of registrations. It is crucial for brand owners and IP professionals to be aware of the latest trends and practices to effectively operate in China’s evolving trademark environment.

A brief look at the numbers

According to the 2024 data from the China National Intellectual Property Administration (CNIPA), the number of filings is down but approval rates are increasing, and Chinese applicants are getting more active internationally. Some key points include:

more than 6 million trademark applications were filed in 2024, down from the year prior;

nearly 5 million trademarks were granted, up from prior years;

the approval rate improved to approximately 71%, compared to 61% the previous year;

by the end of 2024, there were 47.6 million valid trademark registrations in China;

Chinese applicants filed more international applications in 2024 via the Madrid System, up from years prior;

administrative cases are being handled more efficiently, with approximately 383,000 appeal cases concluded and about 103,000 opposition cases concluded in 2024; and

around 470,000 cases of malicious registrations were cracked down on in 2023, up about 27% from 2022.

All in all, while we see a decline in filings, approvals have gone up and the number of valid trademarks has increased overall. This is likely affected by the CNIPA’s policies to combat mass and malicious filings. With many applications being filtered out early, the applications that are examined seem to satisfy the requirements, explaining the higher approval rate, while various administrative proceedings seem to be more quickly and efficiently handled. 

Legal developments

Tightening the requirements for cancellations and evidence of use 

The CNIPA and Chinese courts are stricter on evidence in non-use cancellation proceedings. Singular documents, unverifiable screenshots or informal unauthenticated submissions are no longer sufficient. Registrants must now produce credible and continuous evidence, such as invoices, customs data, contracts and logistics records to demonstrate actual commercial use.

Moreover, recent cases have shown that the CNIPA is more strictly enforcing accurate matching between registered goods and proof of use. Showing evidence of use close to the goods/services in question will no longer be enough. In 2025, the CNIPA also began requiring preliminary proof of non-use when filing for cancellation. 

To ensure better success in the face of non-use cancellation, trademark owners should implement strict record keeping among various areas of business, including production, sales and marketing. Consistent use of the registered trademarks should also be followed. This is particularly vital for enforcement, where cancellation could be detrimental to a case. Broad filings can either be reconsidered or refiling strategies could be implemented to avoid partial and full cancellations.

The declining power of co-existence agreements

Coexistence agreements or letters of consent have long been a strategic choice for applicants facing refusals on relative grounds in China, where an applicant’s mark is deemed similar to an earlier mark. However, over the last couple of years, such agreements have been less accepted by the authorities in China. 

In the past, coexistence agreements and letters of consent were attractive because they allowed parties to avoid extended trademark disputes by negotiating certain limits, such as territories, channels and classes of goods or services. At the same time, Chinese authorities often accepted these agreements as persuasive evidence that confusion would not arise. However, flash-forward to today, and these private agreements are now declining in power. While there is no official regulation barring use of such agreements, even where these agreements are accepted despite the trending decline, it is unpredictable when and how they may be accepted – thus the time and costs associated with negotiating such agreements could prove worthless in the end.

What does this mean in practice? While the use of these agreements is not off the table, do not assume that submitting a coexistence agreement or letter of consent will automatically result in a successful review of refusal. In fact, based on recent trends it would be wiser to assume that they will not be accepted. If a party does decide to submit a coexistence agreement or letter of consent, it can expect to be required to submit additional evidence to prove the authenticity of the agreements (eg, notarisation/legalisation of documents or related commercial documents/actions in line with the agreement). Prioritise earlier filings to avoid risks of being rejected despite any deals to coexist with earlier marks. Where possible, have solid evidence of earlier use to overcome refusals. Be prepared to engage in more oppositions, non-use cancellation actions to remove bad-faith filings and remove potential obstacle in the future. Finally, be prepared for a protracted battle to overcome refusals in light of earlier similar marks.

Revisions to the Trademark Law 

China continues to work on changes to its Trademark Law to improve quality and development and better align with international norms. The CNIPA released a draft amendment for public comment in January 2023, which remains under review. However, in May 2025, China’s State Council included a draft amendment to the Trademark Law in the 2025 Legislative Plan, confirming that the Trademark Law is to be submitted to the Standing Committee of the National People’s Congress for deliberation. 

Some measures expected in the revision include:

further crackdown on bad-faith filings with earlier rejection and more deterrents;

stronger focus on actual use of marks, with the potential for stricter requirements of use;

greater protection of well-known marks;

more efficiency for various administrative procedures; and

increased penalties/fines/damages.

Trademark owners should remain aware of the upcoming changes and be prepared for those that will affect their current strategies and processes. For example, trademark owners should already be prepared to improve practices related to evidence of use, while filing strategies may need to be adjusted to avoid issues with bad-faith filing regulations and non-use requirements. All in all, while the changes are expected to be largely to the benefit of good-faith brand owners, a review of best practices will be necessary amid this shift.

Continued crackdown on bad-faith filings

The CNIPA has been actively removing and rejecting trademarks with no real intent to use. Thousands of bad-faith applications were rejected in 2024 and 2025, and arguing bad faith has become much easier. This will definitely be a continuing trend with new regulations and the upcoming revision to the Trademark Law. Trademark owners should look back at existing bad-faith marks and develop a strategy to remove them as early as possible to avoid having them registered for more than five years and thus potentially they become more difficult to remove.

Takeaways for brand owners and IP professionals

The overall effect of the recent changes is that China’s trademark system is maturing. The CNIPA and Chinese government is seeking to increase genuine market activity, reduce and remove bad-faith behaviour, raise the value of legitimate evidence in IP cases and become more international overall. This is a welcome development, but it is also critical for parties to prioritise using their marks in China, place greater emphasis on continued maintenance and compliance, and take the chance to review their current practice to take advantage of the tools becoming available.