A partial refusal does not mean that every accepted item will be lost unless the applicant pays for division. Nor does a non-use evidence response automatically come with the three-month supplementation period found in review proceedings. Both misunderstandings appear in questions submitted to CNIPA.
This FAQ selects seven practical traps from CNIPA's registration and review consultation replies, checked on 26 October 2026. It complements our registration and ownership FAQ and review procedure FAQ. It is MY CNTM's English paraphrase and commentary, not an official CNIPA translation. We omit the correspondents' identities and registration numbers.
Each answer links to its official source. Where a reply displays only a day and month, or no date, we do not invent a year. Older replies are identified and should be applied with the current law, actual notice and filing channel. The linked 2027 transition proposals remain a separate consultation topic.
Seven mistakes to avoid
If I do not divide a partially refused application, will the accepted goods be abandoned too?
No, that is not what CNIPA's published answer says. In its reply dated 14 August 2026, CNIPA says the approved portion will proceed to preliminary approval publication. Where the applicant neither divides nor seeks review, no additional action is needed for that portion to continue through the subsequent process.
Practical observation: distinguish the refused items from those that passed examination. Division and review serve different purposes; neither should be sold as automatically necessary to preserve every accepted item. Choosing not to challenge the refusal still has consequences for the refused items. Publication is also not the same milestone as final registration.
Official reply: partial refusal without division or review, 14 August 2026. See our division guide and practice note on the surviving goods after partial refusal.
Can I submit an outline in a non-use cancellation response and assume I have another three months for evidence?
Do not assume that. A registration consultation reply explains that the respondent must complete its response within the response period and that the three-month supplementation period for review proceedings does not apply to the initial non-use cancellation proceeding. If further material is intended, the reply says to explain that in the first response; it does not grant a new statutory three-month window. The page displays 26 May without a year.
A separate reply dated 27 February 2023 concerns the later review of a non-use cancellation decision. It describes declaring the need for supplementary evidence in the review application or review response and submitting it within the specified three-month period. Those two replies concern different procedural stages.
Practical observation: read the actual evidence notice, identify the stage and organise the evidence before its deadline. A statement that more material will follow is not an extension or a guarantee that late material will be admitted.
Official initial non-use response answer; official cancellation-review supplementation answer, 27 February 2023. See our deadline guide.
Can related companies transfer just one mark and leave behind other similar marks?
Common ownership is not an automatic exemption. The published question asks whether evidence of the relationship between an assignor and assignee allows them to avoid transferring related marks together. CNIPA answers that the required marks must still be assigned together. The reply does not display a dated answer in the text checked.
Practical observation: examine the seller's portfolio before fixing the transaction schedule. The underlying test concerns the relevant identical or similar marks on identical or similar goods, rather than a rule that everything in one class must be sold or that different classes can never matter. A group-company relationship does not resolve that examination.
Official reply: assignment between affiliated companies. See our assignment correction case on related marks.
Can I assign only one class within a single domestic multi-class registration number?
The reply to that domestic registration question says to transfer all classes under the registration number together. CNIPA also notes the related-mark requirement and that applications liable to cause confusion or other adverse effects may not be approved. The source displays 8 January without a year and says the official examination documents determine the particular result.
Practical observation: a class-based price does not create a right to split the ownership of a registration. MY CNTM's subsequent services are billed per mark per class, including where one number covers multiple classes. That commercial billing unit is different from the legal unit that can be assigned. This domestic reply should not be generalised into a rule on every partial change of ownership under the Madrid system.
Official reply: assignment of a three-class registration. See our assignment guide.
Our company changed its name twice; can we update only the marks shown under the latest old name?
Do not overlook the earlier names. In the situation addressed on 5 June 2026, different registrations remained under two former names of the same entity. CNIPA says the change applications can be submitted in two batches with the corresponding name-change documents. The question arose after an incomplete portfolio update prompted a correction.
Practical observation: search the portfolio under each historical name and assemble the documentary chain to the current name. Separate batches are an administrative way to handle that chain, not an exemption allowing part of the relevant portfolio to be ignored. Confirm that the documents establish continuity of the same legal entity; an ownership change may require a different procedure.
Official reply: registrations under multiple former names, 5 June 2026. See our ongoing duties guide.
After registration, must I keep using the original agent for renewal or other subsequent business?
No. In response to a registered owner asking how to replace the original agent, CNIPA says subsequent business can be entrusted directly to a new agency. The page displays 6 July without a year.
Practical observation: appointing a new agent for a new matter is not necessarily the same action as changing the agent in an existing application or changing a document recipient. Confirm the authority and correspondence arrangements for each live proceeding. A new renewal instruction should not be assumed to redirect every outstanding notice or discharge a response deadline in another case.
Official reply: engaging a new agency for subsequent business. See our agent versus document recipient guide.
Does a trademark licence or its recordal make the licensee the owner?
No. CNIPA's reply distinguishes the two transactions: assignment changes trademark ownership; licence recordal does not. It also explains that licence recordal is to be sought during the licence contract's effective term and should identify the parties, term, licence type and permitted goods or services. The page displays 28 June without a year.
Practical observation: choose the procedure according to whether the parties intend to transfer ownership or authorise use. A signed licence, a recordal application and approval of an assignment are different documents with different functions. This FAQ does not reproduce the reply's historical fee figures or processing estimates as current service prices or guaranteed times.
Official reply: assignment versus licence recordal. See our licence recordal guide.
A check before giving instructions
Our practical recommendation is to identify the precise proceeding, accepted and refused goods, legal owner, registration numbers, relevant classes and actual deadline before ordering a service. For an assignment, examine the wider portfolio; for a corporate update, check former names; for evidence, distinguish the first proceeding from a later review.
None of these public replies decides a private service-fee dispute or guarantees approval of a new application. For foreign owners, general online filing answers also do not displace the applicable requirement to use a Chinese agency where the owner lacks a habitual residence or business office in China.
More source-based practical answers
Our additional FAQ selections cover documents and priority, electronic service and evidence and portfolio procedures. Each answer links to its public source and distinguishes procedural guidance from our practical recommendations.
Official sources and scope
The eight individual CNIPA consultation replies are linked beside the seven answers above. They come from the registration consultation archive and review consultation archive. This is a selected collection, not a claim that all archived replies remain current in every detail. Our editorial standards explain how we distinguish public sources, English paraphrases and our recommendations.