China’s IP Administration Publishes Measures on Transitional Arrangements for the Implementation of the New Trademark Law
Published 29 September 2026
Sarah Xuan
On 28 September 2026, the China National Intellectual Property Administration (CNIPA) issued a notice seeking public comments on the Measures for Handling Matters Relating to the Implementation of the Revised Trademark Law (Draft for Comments) (the “Measures”), with comments to be submitted before 12 November 2026. This consultation is intended to support the implementation of the Trademark Law of the People’s Republic of China, revised and adopted on 26 June 2026 and due to enter into force on 1 January 2027 (the “New Law”), by addressing the transition between the old and new regimes and the practical implementation of newly introduced mechanisms.
According to the explanatory notes on the drafting of the Measures, the Regulations for the Implementation of the Trademark Law are still being revised. The Measures therefore serve two functions: to clarify which rules apply to trademark matters spanning the date on which the New Law enters into force, and to provide an operational basis for matters such as the registration of motion signs, ex officio revocation and the recognition of well-known trademarks. Comprising ten articles, the Measures are intended to enter into force concurrently with the New Law, but remain a draft for comments at present.
For applicants and trademark owners, the transitional arrangements directly affect the examination standards applicable to pending applications, opposition periods, the mechanisms by which registered trademark rights may cease, and the obligations relating to the management of existing trademarks. Understanding these provisions requires consideration of both the type of matter and the relevant dates, so as to avoid determining the applicable law in every case solely by reference to the filing date or the date of the decision. The principal transitional arrangements and their implications are summarised below.
(I) Determining the Application of the Old and New Laws by Type of Matter Article 2 of the Measures provides different arrangements for three categories of matters. Applications for registration, opposition, review of refusal, review of a decision not to register, modification, assignment, renewal, cancellation, recordal of a licence and other matters filed before 1 January 2027 are, in principle, subject to the New Law where CNIPA issues an administrative decision or ruling on or after that date. Accordingly, filing an application before the New Law enters into force does not necessarily mean that all subsequent examination will continue to be governed by the old law.
For trademarks whose registration was approved before 1 January 2027, where a decision or ruling in an invalidation case or a review of an invalidation decision is issued on or after that date, procedural issues are governed by the New Law, while substantive issues are governed by the Trademark Law in force when registration of the trademark was approved. The applicable substantive law may therefore be an earlier version of the Trademark Law and should not invariably be understood to mean the text as amended in 2019. For applications for revocation or review of a revocation decision filed before 1 January 2027, where a decision is issued on or after that date, procedural issues are governed by the New Law and substantive issues by the Trademark Law in force before the revision.
These distinctions accommodate both the consistent handling of pending matters and the stability of existing registered rights. Although the explanatory notes summarise the transitional principle as “the old law governs substantive issues and the new law governs procedural issues”, the individual paragraphs of Article 2 and other special provisions must govern the handling of particular matters. For example, grounds for invalidating an existing trademark should be formulated under the law in force at the time of registration, whereas pending applications for registration require a reassessment of the registration requirements under the New Law. Case management records should separately identify the filing date, the date on which registration was approved and the date of the decision, so that the version of the law on which the arguments are based can be determined accordingly.
(II) Clarifying Application Materials and Distinctiveness Requirements for the Registration of Motion Signs Article 14 of the New Law expressly includes motion signs among the elements eligible for trademark registration. The subject matter of protection encompasses the form in which a sign changes continuously, addressing the need for identification in commercial settings such as digital interfaces and brand animations. A dynamic presentation does not, however, in itself establish trademark distinctiveness: the sign must still satisfy the source-identification requirements under Article 17 and is subject to the restrictions on the registration of functional elements under Article 18.
Article 3 of the Measures proposes that, from 1 January 2027, an applicant must declare in the application that registration is sought for a motion sign, explain how it is to be used, and submit a specimen and description that are consistent with each other. The specimen must include an MP4 video showing the complete sequence of motion, with a file size not exceeding 20 MB, together with three to nine static JPEG frames adequately depicting that sequence.
The Measures specifically note that moving images are readily perceived by the public as advertising or product demonstrations and often need to acquire distinctiveness through prolonged or extensive use. CNIPA may, pursuant to Article 33 of the New Law, require an applicant to submit evidence of distinctiveness acquired through use, which the applicant must submit within 15 days of receipt of the notice. This wording does not make acquired distinctiveness a universal prerequisite for all motion trademark applications, but indicates the principal examination difficulty for such applications. Before filing, businesses should settle the specific form of the motion sign and compile materials relating to use, dissemination and market recognition capable of demonstrating that the public perceives it as an indication of commercial origin, so as to meet the short submission deadline.
(III) Determining the Opposition Period by Reference to the Publication Date Article 36 of the New Law shortens the opposition period from the three months prescribed by Article 33 of the old law to two months. Article 4 of the Measures accordingly provides that, for domestic trademark applications, the applicable period is determined by the date of publication of preliminary approval: applications published before 1 January 2027 remain subject to the period under the old law, while those published on or after that date are subject to the period under the New Law. For internationally registered trademarks, the date of publication by the World Intellectual Property Organization determines whether the old or new rules apply.
This arrangement preserves opposition periods that have already begun to run before the New Law enters into force. For example, the opposition period for a trademark whose preliminary approval is published in December 2026 will not automatically be shortened by the entry into force of the New Law, even if that period extends into 2027. Conversely, an application filed in 2026 whose preliminary approval is not published until 2027 will be subject to the period prescribed by the New Law.
A shorter opposition period helps expedite the registration of unopposed trademarks, but also reduces the time available to rights holders for monitoring, assessment and preparation. Businesses and agencies will need to adjust their publication-monitoring and internal authorisation procedures accordingly and, in particular, avoid applying a uniform two-month period to all cases during the transition. Deadlines in international registration cases must also be calculated in accordance with the procedures specific to those cases; the method used for domestic publications of preliminary approval cannot simply be applied to them.
(IV) Separate Transitional Rules for the Termination of Rights upon Voluntary Cancellation and the Blocking Period Article 48 of the New Law provides that, where a registrant applies for cancellation in whole or in part, the corresponding exclusive right to use the trademark terminates on the date of publication following approval of the cancellation. Compared with Article 73 of the current Regulations for the Implementation of the Trademark Law, under which the right terminates on the date the Trademark Office receives the cancellation application, the New Law moves the termination date to the publication date. Article 5 of the Measures proposes applying this rule to cancellation applications filed on or after 1 January 2027. Settlement or brand exit arrangements involving cancellation should specify the relevant milestones for performance accordingly; the mere filing of a cancellation application cannot be treated as establishing that the relevant rights have terminated.
Relatedly, Article 49 of the New Law redefines the scope of the one-year blocking period. Article 50 of the old law precludes approval of identical or similar trademarks for one year following revocation, invalidation or expiry without renewal of a trademark. The New Law instead provides that, where a registrant applies for cancellation, applications by others for identical or similar trademarks in respect of identical or similar goods will not be approved for one year from the date of publication of the cancellation. Article 6 of the Measures uses the date of the decision or ruling as the dividing line and provides that Article 49 of the New Law applies from 1 January 2027.
This change will affect the choice of strategies for removing obstacles posed by earlier trademarks. Under the New Law, voluntary cancellation may continue to restrict subsequent registration by others for one year, whereas revocation, invalidation and expiry without renewal are no longer among the grounds for a blocking period listed in Article 49. Of course, the absence of a blocking-period restriction does not mean that a later application will necessarily be approved: the status of prior rights and the other registration requirements must still be verified. The time implications of negotiated cancellation, trademark assignment and contested proceedings should therefore be assessed separately in light of the new rules.
(V) Bringing the Continued Use of Existing Trademarks within the New Law’s Regulatory Framework Article 56 of the New Law specifically addresses the use of registered trademarks in a manner that misleads the public: the enforcement authority is to order rectification within a specified period and may impose a fine in accordance with the law; if rectification is not made within that period, the trademark administration department under the State Council is to revoke the registered trademark. Article 7, paragraph 1 of the Measures clarifies that the New Law applies to trademarks whose registration was approved before 1 January 2027 where the relevant misleading use continues on or after that date.
This provision focuses scrutiny on the way in which a trademark is actually used. A trademark that has already been registered may still be subject to regulation where its packaging, promotion or specific presentation misleads the public; where conduct continues beyond the date of entry into force, an earlier registration date does not exclude the application of the New Law. Before the New Law enters into force, businesses should examine the relationship between actual use and product information and promptly adjust presentations that may be misleading.
Article 57, paragraph 3 of the New Law also empowers the trademark administration department under the State Council to revoke registered trademarks ex officio where they have not been used for three consecutive years without justifiable reasons or have become the generic names of the goods for which they are registered. Article 7, paragraph 2 of the Measures proposes applying this mechanism to trademarks whose registration was approved before the New Law enters into force and specifies that local trademark administration departments at the prescribed levels are to investigate, verify and report the matter through successive administrative levels. If CNIPA considers that the conditions for revocation are met, it must notify the registrant to submit evidence before issuing a decision in accordance with the law.
This introduces a further route by which administrative authorities may initiate the removal of unused trademarks or trademarks that have become generic. Registrants need to maintain evidence of genuine use on an ongoing basis and prevent their trademarks from degenerating into generic names for goods in trade. At the same time, the draft does not specify the reference point for calculating the three-year period in ex officio revocation proceedings or prescribe a deadline for submitting evidence. These issues concern the scope of investigation and registrants’ procedural safeguards and require further clarification in the final rules or supporting documents. It cannot simply be presumed that the three-year period will begin afresh on 1 January 2027.
(VI) Linking Domestic Proceedings and Overseas Enforcement through the Recognition of Well-Known Trademarks Article 63 of the New Law expressly provides that the well-known status of a trademark may be recognised as necessary for the handling of a case in the course of the examination and adjudication of trademark registration matters, the investigation and handling of trademark violations or unfair competition cases, and other proceedings. Article 69, paragraph 1 further provides that, where it is necessary, in the examination and adjudication of trademark registration matters or the handling of trademark cases outside China, to establish that a trademark is well known to the relevant public within China, such recognition may be granted at a party’s request.
Article 8 of the Measures accordingly requires that materials supporting such requests be submitted in accordance with Article 63, paragraph 4 of the New Law, with evidence addressing factors such as the degree of awareness among the public, the duration, manner and geographical extent of trademark use, publicity, and records of protection. For relevant assertions of rights referred by other departments, trademark administration departments must submit the matter through successive administrative levels to CNIPA for recognition. Parties to overseas cases may also submit requests to local trademark administration departments at the levels prescribed in that article, which will refer the requests through successive administrative levels.
This arrangement provides domestic procedural support for businesses seeking to establish their reputation in the Chinese market in overseas cases. Recognition nevertheless remains dependent on the needs of a specific case, and its evidential weight and protective effect in overseas proceedings must be determined by the local authorities under the applicable law. Businesses should organise their records of use, publicity and protection within China by reference to the facts that need to be proved in the overseas dispute, and avoid assuming that domestic recognition of well-known status automatically confers equivalent protection overseas.
(VII) Continued Application of the Implementing Regulations and Examination Guidelines to the Extent Consistent with the New Law Article 9 of the Measures provides that, until the revised implementing regulations enter into force, the current implementing regulations will continue to apply, except for provisions that conflict with the New Law. Where both the New Law and the current regulations address the same matter, the New Law applies. Interpretations and definitions in the current regulations relating to matters under the old law will continue to apply as the corresponding interpretations and definitions where those matters are retained in the New Law. The current Guidelines for Trademark Examination and Adjudication are to be applied by reference to the same principle.
This arrangement maintains continuity in the handling of matters but requires the applicability of the law to be checked provision by provision. Existing procedures and interpretations cannot all cease to apply merely because the regulations have yet to be revised, nor can they take precedence over the New Law merely because they have not yet been formally amended. In handling a particular case, it is necessary first to check whether the New Law already addresses the matter and then to determine whether the existing procedures, interpretations and examination standards remain compatible with it.
Conclusion By specifying the dates that determine the applicable law for different categories of matters and supplementing the procedures for implementing newly introduced mechanisms, the Measures provide the necessary transition to the New Trademark Law. Their practical implications extend across applications, oppositions, the termination of rights and the management of post-registration use: applicable standards must be reassessed in pending cases, publication monitoring must accommodate shorter deadlines, the timing of cancellation and strategies for removing registration obstacles must be recalculated, and existing registered trademarks must also withstand scrutiny under the rules governing continued use.
Further refinement of the transitional rules should continue to focus on predictability. For example, the relationship between the general rule in Article 2 applying the New Law to pending cancellation applications and the special arrangement in Article 5 distinguishing applications by their filing dates should be further clarified as regards applications filed before, but approved after, the New Law enters into force. Clear rules should also be provided for calculating periods and setting evidential submission deadlines in ex officio revocation proceedings. Adequate clarification of these specific issues is necessary to ensure the smooth application of the new regime to existing matters and to provide businesses with stable expectations when adjusting their trademark management and enforcement strategies. Until the final text is issued, these arrangements should be understood as proposals for consultation, and their subsequent implementation will need to reflect the final provisions as published.
According to the explanatory notes on the drafting of the Measures, the Regulations for the Implementation of the Trademark Law are still being revised. The Measures therefore serve two functions: to clarify which rules apply to trademark matters spanning the date on which the New Law enters into force, and to provide an operational basis for matters such as the registration of motion signs, ex officio revocation and the recognition of well-known trademarks. Comprising ten articles, the Measures are intended to enter into force concurrently with the New Law, but remain a draft for comments at present.
For applicants and trademark owners, the transitional arrangements directly affect the examination standards applicable to pending applications, opposition periods, the mechanisms by which registered trademark rights may cease, and the obligations relating to the management of existing trademarks. Understanding these provisions requires consideration of both the type of matter and the relevant dates, so as to avoid determining the applicable law in every case solely by reference to the filing date or the date of the decision. The principal transitional arrangements and their implications are summarised below.
(I) Determining the Application of the Old and New Laws by Type of Matter Article 2 of the Measures provides different arrangements for three categories of matters. Applications for registration, opposition, review of refusal, review of a decision not to register, modification, assignment, renewal, cancellation, recordal of a licence and other matters filed before 1 January 2027 are, in principle, subject to the New Law where CNIPA issues an administrative decision or ruling on or after that date. Accordingly, filing an application before the New Law enters into force does not necessarily mean that all subsequent examination will continue to be governed by the old law.
For trademarks whose registration was approved before 1 January 2027, where a decision or ruling in an invalidation case or a review of an invalidation decision is issued on or after that date, procedural issues are governed by the New Law, while substantive issues are governed by the Trademark Law in force when registration of the trademark was approved. The applicable substantive law may therefore be an earlier version of the Trademark Law and should not invariably be understood to mean the text as amended in 2019. For applications for revocation or review of a revocation decision filed before 1 January 2027, where a decision is issued on or after that date, procedural issues are governed by the New Law and substantive issues by the Trademark Law in force before the revision.
These distinctions accommodate both the consistent handling of pending matters and the stability of existing registered rights. Although the explanatory notes summarise the transitional principle as “the old law governs substantive issues and the new law governs procedural issues”, the individual paragraphs of Article 2 and other special provisions must govern the handling of particular matters. For example, grounds for invalidating an existing trademark should be formulated under the law in force at the time of registration, whereas pending applications for registration require a reassessment of the registration requirements under the New Law. Case management records should separately identify the filing date, the date on which registration was approved and the date of the decision, so that the version of the law on which the arguments are based can be determined accordingly.
(II) Clarifying Application Materials and Distinctiveness Requirements for the Registration of Motion Signs Article 14 of the New Law expressly includes motion signs among the elements eligible for trademark registration. The subject matter of protection encompasses the form in which a sign changes continuously, addressing the need for identification in commercial settings such as digital interfaces and brand animations. A dynamic presentation does not, however, in itself establish trademark distinctiveness: the sign must still satisfy the source-identification requirements under Article 17 and is subject to the restrictions on the registration of functional elements under Article 18.
Article 3 of the Measures proposes that, from 1 January 2027, an applicant must declare in the application that registration is sought for a motion sign, explain how it is to be used, and submit a specimen and description that are consistent with each other. The specimen must include an MP4 video showing the complete sequence of motion, with a file size not exceeding 20 MB, together with three to nine static JPEG frames adequately depicting that sequence.
The Measures specifically note that moving images are readily perceived by the public as advertising or product demonstrations and often need to acquire distinctiveness through prolonged or extensive use. CNIPA may, pursuant to Article 33 of the New Law, require an applicant to submit evidence of distinctiveness acquired through use, which the applicant must submit within 15 days of receipt of the notice. This wording does not make acquired distinctiveness a universal prerequisite for all motion trademark applications, but indicates the principal examination difficulty for such applications. Before filing, businesses should settle the specific form of the motion sign and compile materials relating to use, dissemination and market recognition capable of demonstrating that the public perceives it as an indication of commercial origin, so as to meet the short submission deadline.
(III) Determining the Opposition Period by Reference to the Publication Date Article 36 of the New Law shortens the opposition period from the three months prescribed by Article 33 of the old law to two months. Article 4 of the Measures accordingly provides that, for domestic trademark applications, the applicable period is determined by the date of publication of preliminary approval: applications published before 1 January 2027 remain subject to the period under the old law, while those published on or after that date are subject to the period under the New Law. For internationally registered trademarks, the date of publication by the World Intellectual Property Organization determines whether the old or new rules apply.
This arrangement preserves opposition periods that have already begun to run before the New Law enters into force. For example, the opposition period for a trademark whose preliminary approval is published in December 2026 will not automatically be shortened by the entry into force of the New Law, even if that period extends into 2027. Conversely, an application filed in 2026 whose preliminary approval is not published until 2027 will be subject to the period prescribed by the New Law.
A shorter opposition period helps expedite the registration of unopposed trademarks, but also reduces the time available to rights holders for monitoring, assessment and preparation. Businesses and agencies will need to adjust their publication-monitoring and internal authorisation procedures accordingly and, in particular, avoid applying a uniform two-month period to all cases during the transition. Deadlines in international registration cases must also be calculated in accordance with the procedures specific to those cases; the method used for domestic publications of preliminary approval cannot simply be applied to them.
(IV) Separate Transitional Rules for the Termination of Rights upon Voluntary Cancellation and the Blocking Period Article 48 of the New Law provides that, where a registrant applies for cancellation in whole or in part, the corresponding exclusive right to use the trademark terminates on the date of publication following approval of the cancellation. Compared with Article 73 of the current Regulations for the Implementation of the Trademark Law, under which the right terminates on the date the Trademark Office receives the cancellation application, the New Law moves the termination date to the publication date. Article 5 of the Measures proposes applying this rule to cancellation applications filed on or after 1 January 2027. Settlement or brand exit arrangements involving cancellation should specify the relevant milestones for performance accordingly; the mere filing of a cancellation application cannot be treated as establishing that the relevant rights have terminated.
Relatedly, Article 49 of the New Law redefines the scope of the one-year blocking period. Article 50 of the old law precludes approval of identical or similar trademarks for one year following revocation, invalidation or expiry without renewal of a trademark. The New Law instead provides that, where a registrant applies for cancellation, applications by others for identical or similar trademarks in respect of identical or similar goods will not be approved for one year from the date of publication of the cancellation. Article 6 of the Measures uses the date of the decision or ruling as the dividing line and provides that Article 49 of the New Law applies from 1 January 2027.
This change will affect the choice of strategies for removing obstacles posed by earlier trademarks. Under the New Law, voluntary cancellation may continue to restrict subsequent registration by others for one year, whereas revocation, invalidation and expiry without renewal are no longer among the grounds for a blocking period listed in Article 49. Of course, the absence of a blocking-period restriction does not mean that a later application will necessarily be approved: the status of prior rights and the other registration requirements must still be verified. The time implications of negotiated cancellation, trademark assignment and contested proceedings should therefore be assessed separately in light of the new rules.
(V) Bringing the Continued Use of Existing Trademarks within the New Law’s Regulatory Framework Article 56 of the New Law specifically addresses the use of registered trademarks in a manner that misleads the public: the enforcement authority is to order rectification within a specified period and may impose a fine in accordance with the law; if rectification is not made within that period, the trademark administration department under the State Council is to revoke the registered trademark. Article 7, paragraph 1 of the Measures clarifies that the New Law applies to trademarks whose registration was approved before 1 January 2027 where the relevant misleading use continues on or after that date.
This provision focuses scrutiny on the way in which a trademark is actually used. A trademark that has already been registered may still be subject to regulation where its packaging, promotion or specific presentation misleads the public; where conduct continues beyond the date of entry into force, an earlier registration date does not exclude the application of the New Law. Before the New Law enters into force, businesses should examine the relationship between actual use and product information and promptly adjust presentations that may be misleading.
Article 57, paragraph 3 of the New Law also empowers the trademark administration department under the State Council to revoke registered trademarks ex officio where they have not been used for three consecutive years without justifiable reasons or have become the generic names of the goods for which they are registered. Article 7, paragraph 2 of the Measures proposes applying this mechanism to trademarks whose registration was approved before the New Law enters into force and specifies that local trademark administration departments at the prescribed levels are to investigate, verify and report the matter through successive administrative levels. If CNIPA considers that the conditions for revocation are met, it must notify the registrant to submit evidence before issuing a decision in accordance with the law.
This introduces a further route by which administrative authorities may initiate the removal of unused trademarks or trademarks that have become generic. Registrants need to maintain evidence of genuine use on an ongoing basis and prevent their trademarks from degenerating into generic names for goods in trade. At the same time, the draft does not specify the reference point for calculating the three-year period in ex officio revocation proceedings or prescribe a deadline for submitting evidence. These issues concern the scope of investigation and registrants’ procedural safeguards and require further clarification in the final rules or supporting documents. It cannot simply be presumed that the three-year period will begin afresh on 1 January 2027.
(VI) Linking Domestic Proceedings and Overseas Enforcement through the Recognition of Well-Known Trademarks Article 63 of the New Law expressly provides that the well-known status of a trademark may be recognised as necessary for the handling of a case in the course of the examination and adjudication of trademark registration matters, the investigation and handling of trademark violations or unfair competition cases, and other proceedings. Article 69, paragraph 1 further provides that, where it is necessary, in the examination and adjudication of trademark registration matters or the handling of trademark cases outside China, to establish that a trademark is well known to the relevant public within China, such recognition may be granted at a party’s request.
Article 8 of the Measures accordingly requires that materials supporting such requests be submitted in accordance with Article 63, paragraph 4 of the New Law, with evidence addressing factors such as the degree of awareness among the public, the duration, manner and geographical extent of trademark use, publicity, and records of protection. For relevant assertions of rights referred by other departments, trademark administration departments must submit the matter through successive administrative levels to CNIPA for recognition. Parties to overseas cases may also submit requests to local trademark administration departments at the levels prescribed in that article, which will refer the requests through successive administrative levels.
This arrangement provides domestic procedural support for businesses seeking to establish their reputation in the Chinese market in overseas cases. Recognition nevertheless remains dependent on the needs of a specific case, and its evidential weight and protective effect in overseas proceedings must be determined by the local authorities under the applicable law. Businesses should organise their records of use, publicity and protection within China by reference to the facts that need to be proved in the overseas dispute, and avoid assuming that domestic recognition of well-known status automatically confers equivalent protection overseas.
(VII) Continued Application of the Implementing Regulations and Examination Guidelines to the Extent Consistent with the New Law Article 9 of the Measures provides that, until the revised implementing regulations enter into force, the current implementing regulations will continue to apply, except for provisions that conflict with the New Law. Where both the New Law and the current regulations address the same matter, the New Law applies. Interpretations and definitions in the current regulations relating to matters under the old law will continue to apply as the corresponding interpretations and definitions where those matters are retained in the New Law. The current Guidelines for Trademark Examination and Adjudication are to be applied by reference to the same principle.
This arrangement maintains continuity in the handling of matters but requires the applicability of the law to be checked provision by provision. Existing procedures and interpretations cannot all cease to apply merely because the regulations have yet to be revised, nor can they take precedence over the New Law merely because they have not yet been formally amended. In handling a particular case, it is necessary first to check whether the New Law already addresses the matter and then to determine whether the existing procedures, interpretations and examination standards remain compatible with it.
Conclusion By specifying the dates that determine the applicable law for different categories of matters and supplementing the procedures for implementing newly introduced mechanisms, the Measures provide the necessary transition to the New Trademark Law. Their practical implications extend across applications, oppositions, the termination of rights and the management of post-registration use: applicable standards must be reassessed in pending cases, publication monitoring must accommodate shorter deadlines, the timing of cancellation and strategies for removing registration obstacles must be recalculated, and existing registered trademarks must also withstand scrutiny under the rules governing continued use.
Further refinement of the transitional rules should continue to focus on predictability. For example, the relationship between the general rule in Article 2 applying the New Law to pending cancellation applications and the special arrangement in Article 5 distinguishing applications by their filing dates should be further clarified as regards applications filed before, but approved after, the New Law enters into force. Clear rules should also be provided for calculating periods and setting evidential submission deadlines in ex officio revocation proceedings. Adequate clarification of these specific issues is necessary to ensure the smooth application of the new regime to existing matters and to provide businesses with stable expectations when adjusting their trademark management and enforcement strategies. Until the final text is issued, these arrangements should be understood as proposals for consultation, and their subsequent implementation will need to reflect the final provisions as published.