Priorities for Trademark Protection by Multinational Enterprises - China’s White Paper on Intellectual Property Protection
Published 8 May 2026
Sarah Xuan
On May 7, 2026, the China National Intellectual Property Administration released the White Paper on the Status of Intellectual Property Protection in China 2025, providing a systematic summary of China’s intellectual property protection work in 2025. As an annual observation document concerning the operation of China’s intellectual property protection system, the value of the White Paper lies not only in presenting the achievements of administrative authorities, judicial organs and relevant departments, but also in conveying to market participants the policy orientation, enforcement priorities and institutional evolution of China’s intellectual property protection regime. For multinational enterprises operating in China, understanding the protection trends reflected in the White Paper is not only significant from a compliance perspective, but also directly relates to the security of their brand assets and the stability of their commercial operations in the Chinese market.
Set out below is our analysis and relevant summary of the White Paper on the Status of Intellectual Property Protection in China 2025.
I. Multinational Enterprises Should Attach Greater Importance to Proactive Trademark Planning in China The White Paper indicates that, in 2025, the number of trademark registrations in China was 4.206 million; by the end of 2025, the number of valid registered trademarks had reached 3.032 million. At the same time, the number of trademark opposition applications was 111,300, and the number of applications for various types of trademark review and adjudication cases was 351,600. This set of data shows that competition for brand-identification resources in the Chinese market remains intense, and trademark conflicts often do not arise after products are launched, but rather occur in advance in right-confirmation procedures such as application, opposition, invalidation, cancellation review and the like.
This point is particularly important for multinational enterprises operating in China. Many enterprises already have mature brand systems globally, but in the Chinese market they may still encounter bad-faith filings because they have not made timely arrangements for Chinese-language brands, transliterated names, abbreviations, product series names, figurative marks, slogans, packaging and trade dress, or derivative brands. In practice, foreign trademarks do not automatically obtain registered protection in China. Even if a brand enjoys a high degree of recognition in the international market, specific protection must still be pursued in light of systems under the Chinese Trademark Law, including registration, use, well-known trademark recognition, prior rights and adverse effects.
Therefore, multinational enterprises should not regard Chinese trademark applications merely as routine filings within a global trademark portfolio. For English trademarks, Chinese translations, nicknames commonly used by consumers, product line names, key figurative elements, packaging-identification elements and signs that may be used on e-commerce platforms, social media and offline stores, enterprises should conduct searches, file applications and carry out defensive planning as early as possible. In particular, before new product launches, co-branding collaborations, brand upgrades and localized marketing campaigns, enterprises should ensure that the progress of Chinese trademark applications, class coverage and ownership of rights are capable of supporting the actual commercial arrangements.
II. Enterprises Should Make Good Use of Opposition, Invalidation and Monitoring Mechanisms The White Paper reflects China’s continued strengthening of governance over bad-faith registrations, trademark hoarding and trademark violations. For a long time, bad-faith preemptive registrations, copying others’ brand identifiers, preemptively registering Chinese brand names, or hoarding similar trademarks in non-core classes have been among the relatively common risks faced by multinational enterprises in trademark protection in China. In recent years, Chinese trademark examination and administrative adjudication practice has paid greater attention to the requirement of “purpose of use,” and has also become more inclined to regulate conduct that clearly lacks genuine intent to use, involves bulk filings, or free-rides on another party’s goodwill.
However, a stricter system does not mean that rights holders may passively wait for administrative authorities to undertake clean-up actions on their own initiative. For multinational brand enterprises, trademark monitoring remains key to preventing the spread of risks. Enterprises should establish regular monitoring for core trademarks, Chinese translations, transliterated signs, abbreviations, figurative marks and high-risk classes of goods and services. Once a similar application is identified, measures such as opposition, invalidation, non-use cancellation, administrative complaint or civil litigation should be taken in a timely manner according to the circumstances of the case. For applicants with clear bad faith, enterprises should also collect records of their bulk applications, historical targets of preemptive registration, affiliated companies, evidence of actual use and sales conduct, so as to strengthen the basis for a finding of bad faith.
Multinational enterprises should also re-examine their own defensive filing strategies. China is strengthening governance over abnormal applications and trademark hoarding. When carrying out protective planning, enterprises should avoid excessive reliance on large-scale applications that lack genuine commercial plans. A more prudent approach is to build a trademark portfolio based on actual brand use, reasonable extensions, channel scenarios and risk classes, and to retain materials such as internal business plans, product development records, marketing promotions or licensing arrangements, so that the legitimacy of the applications can be explained when necessary.
III. Enterprises Should Enhance Their Localized Enforcement Response Capabilities The White Paper discloses that, in 2025, market regulation authorities at all levels nationwide investigated and handled approximately 36,000 trademark violation cases, involving an amount of RMB 674 million, and transferred 1,128 suspected criminal cases to judicial authorities in accordance with the law. The typical cases of administrative trademark protection listed in the White Paper show that administrative authorities conducted centralized investigations and enforcement against the sale of counterfeit branded goods by stores in multiple locations, as well as chain-based and large-scale infringement, and achieved governance through measures such as confiscation of infringing goods, fines and transfer of suspected criminal cases.
For multinational enterprises operating in China, administrative protection still has outstanding practical value in China. Compared with civil litigation, administrative complaints are generally more suitable for addressing the sale of counterfeit goods by offline stores, warehouse dens, wholesale markets, trade show infringements, regional counterfeiting and clear trademark counterfeiting cases. In particular, where infringing goods circulate rapidly, evidence may be lost, or sales need to be stopped immediately, administrative authorities’ mechanisms of on-site inspection, sealing and seizure, and penalties can effectively disrupt the infringement chain.
However, the effectiveness of administrative protection is highly dependent on the quality of the rights holder’s preparation. Enterprises should ensure the completeness of Chinese trademark registration certificates, chain of title, authorization documents, evidence of use of Chinese translations and genuine-product identification materials, and establish efficient communication mechanisms with legal counsel in China, investigation agencies, market regulation authorities and customs. For structures in which trademarks are held by foreign entities while business operations are conducted by domestic subsidiaries, arrangements concerning the complainant’s standing, powers of attorney, notarization and legalization, or the use of electronic supporting documents should also be clarified in advance, so as to avoid delays in action during the enforcement window due to incomplete materials.
In the Chinese market, infringement often exhibits characteristics of online traffic diversion, offline delivery, cross-regional warehousing and multi-entity division of labor. Enterprises need to incorporate administrative complaints into a broader enforcement strategy and coordinate them with platform complaints, evidence preservation, civil claims and criminal reports, rather than using them as isolated tools.
IV. Enterprises Should Strengthen Their Evidence Systems and Claims Strategies The White Paper indicates that, in 2025, courts nationwide heard a large number of intellectual property civil cases, and reflected through typical cases a judicial orientation toward strengthening protection, increasing damages and applying punitive damages.
In enforcing rights in China, rights holders often face a practical issue: the commercial harm caused by infringement is substantial, but visible sales data is limited, the infringer’s financial materials are difficult to obtain, platform pages may be deleted at any time, and offline transactions are relatively concealed. The judicial protection trends reflected in the White Paper suggest that rights holders should build an evidentiary structure around the “scale of infringement” and “subjective bad faith” from the early stages of a case, rather than merely proving trademark similarity and similarity of goods.
In practice, enterprises should focus on preserving and organizing the following evidence: materials demonstrating the reputation of the trademark in China and globally; sales and promotional materials in the Chinese market; sales links, sales volumes, reviews and livestreaming records of infringing goods; offline purchases and notarized evidence-collection materials; records showing that the infringer has previously been subject to complaints, penalties or judgments; cease-and-desist letters and facts showing the other party’s continued infringement; and information on the geographic coverage, channel levels, warehousing and logistics of infringing goods. For infringement cases that are repetitive, chain-based or clearly intended to free-ride, enterprises should actively assess the possibility of applying punitive damages, rules on evidence obstruction and preliminary injunctions.
Judicial protection should also match commercial objectives. For core brands, strategic new products and key channels, the objective of litigation may not only be to obtain damages, but also to establish market boundaries, clean up distribution channels, promote platform governance and disrupt counterfeit ecosystems. For enterprises with global brand governance systems, China litigation strategies should be incorporated into the overall brand protection budget and risk management framework, rather than being assessed merely as costs of individual cases.
V. Enterprises Should Shift from “Takedown Complaints” to Platform Ecosystem Governance The White Paper mentions that special campaigns such as “Sword Net 2025” focused on regulating market order in areas including online sales, online storage and dissemination, and streaming media smart terminals. Although the relevant statements are mainly concentrated on copyright protection, the regulatory direction reflected therein is equally applicable to trademark and brand protection: intellectual property infringement is migrating toward platform-based, content-based, socialized and cross-border forms, and regulatory authorities are continuously strengthening governance of online platforms and new business models.
Online infringement faced by enterprises operating in China is no longer limited to counterfeit-goods links on traditional e-commerce platforms. More common issues include: store names or profile images using similar signs; short videos and livestreaming rooms diverting traffic by using brand keywords; social media accounts impersonating official channels; influencers confusing genuine goods with imitations in promotions; cross-border platforms selling “same-style” goods; purchase of brand keywords for search advertising; and private-domain channels completing transactions through QR codes, WeChat groups and mini-programs. Such infringement is characterized by rapid dissemination, difficulty in evidence collection, dispersed actors and significant differences among platform rules.
Therefore, enterprises should upgrade online protection from “takedown after discovering a link” to platform ecosystem governance. Enterprises should establish a unified online monitoring system covering major e-commerce platforms, social media, short-video platforms, livestreaming platforms, search engines and cross-border platforms. At the same time, they should distinguish the requirements of different platforms for trademark registration certificates, authorization documents, purchase and authentication reports, rights-holder statements, agency authority and infringement comparison materials, and form standardized complaint packages. For frequent infringers, enterprises should connect platform complaint outcomes with administrative reports, civil litigation and the transfer of criminal leads, so as to prevent infringers from continuing operations by changing stores, accounts or platforms.
VI. Enterprises Should Pay Attention to Risks in Local Cooperation Chains The White Paper includes administrative protection of trade secrets as a key focus, reflecting that China’s anti-unfair competition enforcement is paying greater attention to the protection of enterprises’ business information, technical information and commercial assets. For enterprises with international business operations, trade secret protection and trademark protection are often intertwined at the stages of brand launch, product release and channel cooperation. New Chinese brand names, unreleased product lines, packaging designs, market-launch plans, pricing systems, supplier lists, distribution strategies and co-branding plans may all be leaked before official release or completion of trademark applications, and may then be preemptively registered, imitated or brought to market early by third parties.
In their operations in China, multinational enterprises usually involve cooperation among multiple parties, including headquarters, regional offices, Chinese subsidiaries, advertising agencies, design companies, distributors, OEM manufacturers, e-commerce service providers and platform operators. Insufficient information management at any link may result in leakage of brand assets. Therefore, enterprises should simultaneously establish confidentiality obligations, access permissions, document watermarks, records of materials delivery, non-compete restrictions and departure handover mechanisms during the processes of brand naming, trademark application, packaging development, advertising placement and new product launch. For external suppliers and business partners, contracts should clearly specify intellectual property ownership, confidentiality obligations, prohibition of preemptive registrations, liability for breach and dispute resolution clauses.
VII. Enterprises Should Establish Customs Protection Mechanisms The White Paper indicates that, in 2025, China Customs seized a large volume of import and export goods suspected of infringement, and continued to carry out special campaigns. For multinational brand enterprises, customs protection is an important tool for controlling the cross-border circulation of counterfeit goods. Rights holders should promptly complete intellectual property recordals with China Customs, and regularly update trademark rights status, lists of authorized manufacturers, methods for identifying genuine goods, typical forms of infringement and contact information. For key ports, high-risk goods and repeatedly occurring infringement routes, enterprises may also improve customs identification efficiency through training, case feedback and cross-border enforcement cooperation.
Conclusion The White Paper on the Status of Intellectual Property Protection in China 2025 is not only an annual policy summary, but also a reference coordinate for enterprises’ China intellectual property strategies. Based on it, enterprises may re-examine the following questions: first, whether their China trademark portfolio covers core brands, Chinese-language signs and future business scenarios; second, whether they have established continuous monitoring mechanisms targeting preemptive registrations, counterfeiting and online infringement; third, whether administrative complaints, platform governance, civil litigation, criminal transfers and customs protection have formed coordination; and fourth, whether brand launches, marketing communications and local cooperation have sufficient intellectual property and anti-unfair competition compliance review.
For multinational enterprises operating in China, only by better integrating local resources, more systematically preserving evidence and selecting rights-enforcement paths can they maintain brand value, reduce operational risks and transform intellectual property protection into a long-term competitive advantage in the complex and rapidly changing Chinese market.
Set out below is our analysis and relevant summary of the White Paper on the Status of Intellectual Property Protection in China 2025.
I. Multinational Enterprises Should Attach Greater Importance to Proactive Trademark Planning in China The White Paper indicates that, in 2025, the number of trademark registrations in China was 4.206 million; by the end of 2025, the number of valid registered trademarks had reached 3.032 million. At the same time, the number of trademark opposition applications was 111,300, and the number of applications for various types of trademark review and adjudication cases was 351,600. This set of data shows that competition for brand-identification resources in the Chinese market remains intense, and trademark conflicts often do not arise after products are launched, but rather occur in advance in right-confirmation procedures such as application, opposition, invalidation, cancellation review and the like.
This point is particularly important for multinational enterprises operating in China. Many enterprises already have mature brand systems globally, but in the Chinese market they may still encounter bad-faith filings because they have not made timely arrangements for Chinese-language brands, transliterated names, abbreviations, product series names, figurative marks, slogans, packaging and trade dress, or derivative brands. In practice, foreign trademarks do not automatically obtain registered protection in China. Even if a brand enjoys a high degree of recognition in the international market, specific protection must still be pursued in light of systems under the Chinese Trademark Law, including registration, use, well-known trademark recognition, prior rights and adverse effects.
Therefore, multinational enterprises should not regard Chinese trademark applications merely as routine filings within a global trademark portfolio. For English trademarks, Chinese translations, nicknames commonly used by consumers, product line names, key figurative elements, packaging-identification elements and signs that may be used on e-commerce platforms, social media and offline stores, enterprises should conduct searches, file applications and carry out defensive planning as early as possible. In particular, before new product launches, co-branding collaborations, brand upgrades and localized marketing campaigns, enterprises should ensure that the progress of Chinese trademark applications, class coverage and ownership of rights are capable of supporting the actual commercial arrangements.
II. Enterprises Should Make Good Use of Opposition, Invalidation and Monitoring Mechanisms The White Paper reflects China’s continued strengthening of governance over bad-faith registrations, trademark hoarding and trademark violations. For a long time, bad-faith preemptive registrations, copying others’ brand identifiers, preemptively registering Chinese brand names, or hoarding similar trademarks in non-core classes have been among the relatively common risks faced by multinational enterprises in trademark protection in China. In recent years, Chinese trademark examination and administrative adjudication practice has paid greater attention to the requirement of “purpose of use,” and has also become more inclined to regulate conduct that clearly lacks genuine intent to use, involves bulk filings, or free-rides on another party’s goodwill.
However, a stricter system does not mean that rights holders may passively wait for administrative authorities to undertake clean-up actions on their own initiative. For multinational brand enterprises, trademark monitoring remains key to preventing the spread of risks. Enterprises should establish regular monitoring for core trademarks, Chinese translations, transliterated signs, abbreviations, figurative marks and high-risk classes of goods and services. Once a similar application is identified, measures such as opposition, invalidation, non-use cancellation, administrative complaint or civil litigation should be taken in a timely manner according to the circumstances of the case. For applicants with clear bad faith, enterprises should also collect records of their bulk applications, historical targets of preemptive registration, affiliated companies, evidence of actual use and sales conduct, so as to strengthen the basis for a finding of bad faith.
Multinational enterprises should also re-examine their own defensive filing strategies. China is strengthening governance over abnormal applications and trademark hoarding. When carrying out protective planning, enterprises should avoid excessive reliance on large-scale applications that lack genuine commercial plans. A more prudent approach is to build a trademark portfolio based on actual brand use, reasonable extensions, channel scenarios and risk classes, and to retain materials such as internal business plans, product development records, marketing promotions or licensing arrangements, so that the legitimacy of the applications can be explained when necessary.
III. Enterprises Should Enhance Their Localized Enforcement Response Capabilities The White Paper discloses that, in 2025, market regulation authorities at all levels nationwide investigated and handled approximately 36,000 trademark violation cases, involving an amount of RMB 674 million, and transferred 1,128 suspected criminal cases to judicial authorities in accordance with the law. The typical cases of administrative trademark protection listed in the White Paper show that administrative authorities conducted centralized investigations and enforcement against the sale of counterfeit branded goods by stores in multiple locations, as well as chain-based and large-scale infringement, and achieved governance through measures such as confiscation of infringing goods, fines and transfer of suspected criminal cases.
For multinational enterprises operating in China, administrative protection still has outstanding practical value in China. Compared with civil litigation, administrative complaints are generally more suitable for addressing the sale of counterfeit goods by offline stores, warehouse dens, wholesale markets, trade show infringements, regional counterfeiting and clear trademark counterfeiting cases. In particular, where infringing goods circulate rapidly, evidence may be lost, or sales need to be stopped immediately, administrative authorities’ mechanisms of on-site inspection, sealing and seizure, and penalties can effectively disrupt the infringement chain.
However, the effectiveness of administrative protection is highly dependent on the quality of the rights holder’s preparation. Enterprises should ensure the completeness of Chinese trademark registration certificates, chain of title, authorization documents, evidence of use of Chinese translations and genuine-product identification materials, and establish efficient communication mechanisms with legal counsel in China, investigation agencies, market regulation authorities and customs. For structures in which trademarks are held by foreign entities while business operations are conducted by domestic subsidiaries, arrangements concerning the complainant’s standing, powers of attorney, notarization and legalization, or the use of electronic supporting documents should also be clarified in advance, so as to avoid delays in action during the enforcement window due to incomplete materials.
In the Chinese market, infringement often exhibits characteristics of online traffic diversion, offline delivery, cross-regional warehousing and multi-entity division of labor. Enterprises need to incorporate administrative complaints into a broader enforcement strategy and coordinate them with platform complaints, evidence preservation, civil claims and criminal reports, rather than using them as isolated tools.
IV. Enterprises Should Strengthen Their Evidence Systems and Claims Strategies The White Paper indicates that, in 2025, courts nationwide heard a large number of intellectual property civil cases, and reflected through typical cases a judicial orientation toward strengthening protection, increasing damages and applying punitive damages.
In enforcing rights in China, rights holders often face a practical issue: the commercial harm caused by infringement is substantial, but visible sales data is limited, the infringer’s financial materials are difficult to obtain, platform pages may be deleted at any time, and offline transactions are relatively concealed. The judicial protection trends reflected in the White Paper suggest that rights holders should build an evidentiary structure around the “scale of infringement” and “subjective bad faith” from the early stages of a case, rather than merely proving trademark similarity and similarity of goods.
In practice, enterprises should focus on preserving and organizing the following evidence: materials demonstrating the reputation of the trademark in China and globally; sales and promotional materials in the Chinese market; sales links, sales volumes, reviews and livestreaming records of infringing goods; offline purchases and notarized evidence-collection materials; records showing that the infringer has previously been subject to complaints, penalties or judgments; cease-and-desist letters and facts showing the other party’s continued infringement; and information on the geographic coverage, channel levels, warehousing and logistics of infringing goods. For infringement cases that are repetitive, chain-based or clearly intended to free-ride, enterprises should actively assess the possibility of applying punitive damages, rules on evidence obstruction and preliminary injunctions.
Judicial protection should also match commercial objectives. For core brands, strategic new products and key channels, the objective of litigation may not only be to obtain damages, but also to establish market boundaries, clean up distribution channels, promote platform governance and disrupt counterfeit ecosystems. For enterprises with global brand governance systems, China litigation strategies should be incorporated into the overall brand protection budget and risk management framework, rather than being assessed merely as costs of individual cases.
V. Enterprises Should Shift from “Takedown Complaints” to Platform Ecosystem Governance The White Paper mentions that special campaigns such as “Sword Net 2025” focused on regulating market order in areas including online sales, online storage and dissemination, and streaming media smart terminals. Although the relevant statements are mainly concentrated on copyright protection, the regulatory direction reflected therein is equally applicable to trademark and brand protection: intellectual property infringement is migrating toward platform-based, content-based, socialized and cross-border forms, and regulatory authorities are continuously strengthening governance of online platforms and new business models.
Online infringement faced by enterprises operating in China is no longer limited to counterfeit-goods links on traditional e-commerce platforms. More common issues include: store names or profile images using similar signs; short videos and livestreaming rooms diverting traffic by using brand keywords; social media accounts impersonating official channels; influencers confusing genuine goods with imitations in promotions; cross-border platforms selling “same-style” goods; purchase of brand keywords for search advertising; and private-domain channels completing transactions through QR codes, WeChat groups and mini-programs. Such infringement is characterized by rapid dissemination, difficulty in evidence collection, dispersed actors and significant differences among platform rules.
Therefore, enterprises should upgrade online protection from “takedown after discovering a link” to platform ecosystem governance. Enterprises should establish a unified online monitoring system covering major e-commerce platforms, social media, short-video platforms, livestreaming platforms, search engines and cross-border platforms. At the same time, they should distinguish the requirements of different platforms for trademark registration certificates, authorization documents, purchase and authentication reports, rights-holder statements, agency authority and infringement comparison materials, and form standardized complaint packages. For frequent infringers, enterprises should connect platform complaint outcomes with administrative reports, civil litigation and the transfer of criminal leads, so as to prevent infringers from continuing operations by changing stores, accounts or platforms.
VI. Enterprises Should Pay Attention to Risks in Local Cooperation Chains The White Paper includes administrative protection of trade secrets as a key focus, reflecting that China’s anti-unfair competition enforcement is paying greater attention to the protection of enterprises’ business information, technical information and commercial assets. For enterprises with international business operations, trade secret protection and trademark protection are often intertwined at the stages of brand launch, product release and channel cooperation. New Chinese brand names, unreleased product lines, packaging designs, market-launch plans, pricing systems, supplier lists, distribution strategies and co-branding plans may all be leaked before official release or completion of trademark applications, and may then be preemptively registered, imitated or brought to market early by third parties.
In their operations in China, multinational enterprises usually involve cooperation among multiple parties, including headquarters, regional offices, Chinese subsidiaries, advertising agencies, design companies, distributors, OEM manufacturers, e-commerce service providers and platform operators. Insufficient information management at any link may result in leakage of brand assets. Therefore, enterprises should simultaneously establish confidentiality obligations, access permissions, document watermarks, records of materials delivery, non-compete restrictions and departure handover mechanisms during the processes of brand naming, trademark application, packaging development, advertising placement and new product launch. For external suppliers and business partners, contracts should clearly specify intellectual property ownership, confidentiality obligations, prohibition of preemptive registrations, liability for breach and dispute resolution clauses.
VII. Enterprises Should Establish Customs Protection Mechanisms The White Paper indicates that, in 2025, China Customs seized a large volume of import and export goods suspected of infringement, and continued to carry out special campaigns. For multinational brand enterprises, customs protection is an important tool for controlling the cross-border circulation of counterfeit goods. Rights holders should promptly complete intellectual property recordals with China Customs, and regularly update trademark rights status, lists of authorized manufacturers, methods for identifying genuine goods, typical forms of infringement and contact information. For key ports, high-risk goods and repeatedly occurring infringement routes, enterprises may also improve customs identification efficiency through training, case feedback and cross-border enforcement cooperation.
Conclusion The White Paper on the Status of Intellectual Property Protection in China 2025 is not only an annual policy summary, but also a reference coordinate for enterprises’ China intellectual property strategies. Based on it, enterprises may re-examine the following questions: first, whether their China trademark portfolio covers core brands, Chinese-language signs and future business scenarios; second, whether they have established continuous monitoring mechanisms targeting preemptive registrations, counterfeiting and online infringement; third, whether administrative complaints, platform governance, civil litigation, criminal transfers and customs protection have formed coordination; and fourth, whether brand launches, marketing communications and local cooperation have sufficient intellectual property and anti-unfair competition compliance review.
For multinational enterprises operating in China, only by better integrating local resources, more systematically preserving evidence and selecting rights-enforcement paths can they maintain brand value, reduce operational risks and transform intellectual property protection into a long-term competitive advantage in the complex and rapidly changing Chinese market.