The filing channel is part of the filing decision

Overseas owners preparing a China trademark application usually spend their thinking on classes and goods wording. The channel the application goes through gets far less attention, yet it settles what the office will accept from that point onwards — how the submission is recorded, what the file is measured against, and what happens to anything sent afterwards.

The office publishes an explanation of its rules for electronic trademark applications, and it answers most of the practical questions that come up when an application goes through the online service system rather than on paper.

What the online service system covers

The online service system opened in full on 26 November 2018, bringing trademark electronic filing and electronic service of trademark documents onto one platform. The rules for electronic applications apply to each type of trademark business that the system has opened up, and the explanation states that this scope widens as the system is developed. Whether a particular matter can be handled online is therefore a question with a moving answer.

The explanation sets out two definitions worth keeping apart. An electronic trademark application is one where a party submits application documents to the office in compliant electronic file form through the online service system. Electronic service of trademark documents is the office delivering trademark documents to the party, again as electronic files, through the same system. Filing electronically and being served electronically are two halves of one arrangement, and the second half is where most deadlines live.

The published rules set out the filing requirements and the procedure at each stage of the registration process and the stages that follow it, distinguishing electronic submissions from paper ones. The office consulted on the draft first, taking in comments from agencies, businesses and the courts.

Setting up before a submission

Two conditions come before any submission. The party signs the user agreement for the online service system, and completes user registration with accurate user information. The explanation then confirms that a party may handle electronic filing on its own account, or appoint a trademark agency to handle it.

For owners based outside mainland China, the second route is the ordinary one: the application is filed through an appointed representative, and the office publishes the standard form of contract for that engagement. That is why the paperwork an overseas applicant is asked for at the start concerns the representative relationship, and why the applicant's own details — the name in Chinese, the address, and the goods and services list — matter from the first submission rather than later.

What makes a submission count as received

Three points from the explanation carry most of the practical weight.

The first is form. A party submitting documents electronically has to follow the required file formats, data standards, operating rules and transmission methods. A submission that does not meet the channel's requirements is not one the system can carry forward.

The second is time, and the third is content. The submission time is the time of receipt recorded by the online service system. What was submitted is taken from the office's archive and its database records. Read together, the two rules put the authoritative record inside the office's system: the receipt time the system logs, and the archive and database the office holds. A local copy, a screenshot of a draft, or a mail thread is not that record.

The fourth point is the one that catches out parties filing electronically for the first time. Once an application has been submitted electronically, the office does not accept follow-up materials in paper form relating to it. The same explanation leaves the office the option of requiring the corresponding paper materials or physical evidence where it considers that necessary. The channel closes in one direction and stays open in the other, which is why a scanned bundle is worth assembling even when the whole matter is handled online.

The deadline side of filing electronically

Filing and service travel together. Under the same explanation, a trademark document delivered electronically is treated as served on the party fifteen days after the date the document was issued. A party that does not log in, or logs in without opening the document, is not treated as being in a situation where service was impossible, and the office does not serve by public announcement instead.

That figure is not a leftover from the system's early days. In April 2026 the office was still confirming to users that electronic service dates run from fifteen days after dispatch, in answer to a question about how the period interacts with the dates shown by the newer filing system. For a party working with a client abroad, the consequence is that the clock on a document can be running before anyone has read it — which is why the reading routine, not the sending routine, decides whether a period is met. Our longer note on that mechanism is linked at the end of this article.

What changed in the online channel itself

On 20 October 2025 the office put a new online filing system into operation. The notice describing the launch sets out the differences that matter to a filer.

Users authenticate through the unified identity authentication system of the national intellectual property public service platform, and the earlier hardware and software digital certificates are no longer used. A user who held an account on the previous system can link it through the unified system and continue with business already submitted there. A mini-program was launched at the same time, covering scan authentication, application enquiries, receipt of electronic documents, fee payment and download of electronic invoices.

The new system also widened what can be handled online. Added to the existing business lines were reviews of decisions refusing registration, reviews of revocation decisions, reviews of declarations of invalidity, recordal of trademark pledges, and applications to revoke a mark that has become a generic name for goods or services. Basic handling information for everything submitted under the previous system can be viewed in the new one, but PDF and JPG files from before 1 July 2024 have to be viewed or downloaded in the previous system.

The direction of travel is the same in both documents: a channel whose scope expands as the system is developed, and a notice that is that expansion happening. For an overseas owner, the practical reading is that the online channel is now the default way a China trademark file is created and maintained, while the paper channel's role is the narrower one — held by the office for evidence, not as the main road.

Frequently asked questions

Does filing electronically change when the application is treated as submitted?

The explanation fixes the submission time as the time of receipt recorded by the online service system, and the content of the submission as what the office's archive and database record. Paper submissions follow the office's separate handling.

After an electronic filing, can supporting materials be sent on paper?

For follow-up materials relating to an application submitted electronically, paper form is not accepted. The explanation keeps one exception in the office's hands: where it considers it necessary, it may require the corresponding paper materials or physical evidence. A paper bundle assembled as the case proceeds is easier to produce than one reconstructed afterwards.

When does a deadline start if documents are served electronically?

Electronic service dates from fifteen days after the date of dispatch, under the rules for electronic applications. Not logging in, or logging in without opening a document, does not turn the matter into one where service was impossible, and service by public announcement is not used instead. The office confirmed the fifteen-day basis to users in April 2026.

Do overseas applicants need their own account in the online system?

Two things come before a submission: signing the user agreement, and completing user registration with accurate information. The explanation confirms that a party may file electronically on its own account or appoint a trademark agency. Applications filed from outside mainland China are made through an appointed representative, and the office publishes the standard form of contract for that appointment.

Which business types can be handled through the online system?

The rules for electronic applications apply to the business types the online service system has opened, and that scope widens as the system is developed. The system launched on 20 October 2025 added reviews of decisions refusing registration, reviews of revocation decisions, reviews of declarations of invalidity, recordal of trademark pledges, and applications to revoke a mark that has become a generic name, to the lines already handled online.

Official sources

Related reading

Check your mark and see the official filing fee for the classes you need — we prepare and file China trademark applications for owners based outside mainland China.

Last reviewed: 6 October 2026