Filing a Chinese trademark from abroad starts with an account

Most foreign brand owners meet the China National Intellectual Property Administration (CNIPA) through a screen rather than a counter. CNIPA operates a trademark online service system: applications are submitted through it in electronic form, and the documents the office produces in the course of examination are delivered back through it as well.

CNIPA's own Frequently Asked Questions on Trademark Electronic Filing describes how that channel works — what it covers, what an account holder is responsible for, and where paper still has a role. It is a working document rather than a statement of principle, which is what makes it useful: it records the range of business the system handles, the rules on withdrawals and replies, and the point that matters most in day-to-day practice, namely when a document counts as delivered.

The FAQ also explains why the office moved in this direction. Trademark documents had long been served by a combination of post and publication, and CNIPA records that postal service suffered delays and losses in practice, which affected how reliably documents reached the parties and how smoothly examination progressed. Electronic delivery removes the transit step altogether.

What the online system is set up to handle

The FAQ records that the online service system handles 24 categories of trademark business, and that any further categories are announced separately rather than added to that list quietly. The 24 fall into a handful of recognisable families.

New filings and their reversal. A trademark registration application, and the withdrawal of a registration application.

Changes to the record. Change of name, address, management rules or the list of members, the last two for collective and certification marks; change of the trademark agent or of the document recipient; and the withdrawal of each of those changes.

The goods and services list. Deletion of goods or services from an application or registration, and withdrawal of that deletion.

Ownership and term. Assignment or transfer, and its withdrawal; renewal, and its withdrawal.

Ending a registration. Cancellation of the registration, and withdrawal of the cancellation.

Licence recordals. Recordal of a licence; withdrawal of the recordal; change of the licensor or licensee named in a recordal; and early termination of a licence recordal.

Certificates, corrections and Madrid matters. Issuing a priority document; issuing a trademark registration certificate for a Madrid international registration; correction of an entry; reissue of a trademark registration certificate; reissue of change, assignment or renewal certificates; and Madrid international registration filings.

Two features stand out to anyone who works with the system regularly. First, most operations arrive as a matched pair — what can be filed can, for the most part, also be withdrawn through the same channel, so a filing submitted in error is pulled back inside the system rather than untangled through correspondence. Second, the scope is not limited to new applications: the record itself, from a changed address to a reissued certificate, is maintained online.

Who submits, and under what agreement. A party may handle a filing itself or appoint a trademark agency established in accordance with Chinese law. Where an agency acts, the agreement with CNIPA is signed by the agency, not by the applicant behind it. Where several applicants jointly apply for the same mark without appointing an agency, the filing is submitted by the representative for that group. Submissions must follow the prescribed document formats, data standards, operating rules and transmission method.

An account carries duties, not just access

Registering is the start of an obligation rather than the end of a formality. The FAQ makes the account holder responsible for the truthfulness, accuracy and completeness of the registration information supplied, and requires that information to be updated through the system whenever it changes. Contact details fall under the same duty: the office validates the email address and the mobile number when they are entered or amended, and uses both channels to notify the user when a document is served.

One distinction is worth keeping in view. A change to the account is made in the account. A change to the trademark registration itself is not an account edit at all — it is handled as a separate change application, which is one of the 24 online business types listed above.

Dormancy has a consequence. An account that is not used for three years is cancelled automatically, and anyone who needs the system again after that must register afresh. For a portfolio that goes quiet for a few years, that is better known in advance than discovered at the point of a deadline.

Electronic in, electronic out

Once a filing goes in electronically, the FAQ states that the office will not accept paper versions of subsequent materials relating to that filing. Replies to the office — correction documents, explanations or amendments, written agreements, certificates, evidence of use — are submitted through the system in electronic form. One door is left open: where necessary, the office may require paper materials or physical evidence to be provided within a period it sets.

Delivery follows the same logic. Electronic service applies where the user has accepted the user agreement for the system and has submitted the application through it; the trademark documents produced in that application are then served electronically only, and not on paper. Applications submitted on paper continue to be served on paper. Electronic service is therefore tied to how the application was filed, not to a preference expressed later.

On timing, the FAQ defines the service date by reference to despatch: a trademark document is treated as served 15 days after the date it is sent to the online system. Periods measured from service — including the period for asking the office to review a refusal — run from that date rather than from the day the document appears in the account. Documents are not despatched on non-working days.

For a foreign applicant the practical effect is that the account, rather than the postbox, is where deadlines begin. A filing made through the system also settles which channel later correspondence will use, so the choice of how to file is a choice about the years that follow.

Frequently asked questions

Can a foreign applicant use the online system directly?

An applicant may handle filings itself or appoint a trademark agency established in accordance with Chinese law. Where an agency acts, the agency signs the user agreement with the office in its own name, and the account sits with the agency. Applications originating outside China are in practice handled through an appointed representative in China, so the representative holds and operates the account on the applicant's behalf. The FAQ sets out the same two routes and the agreement that each requires.

What can still be done online after the application is filed?

Most of what follows a filing can be done in the same system: changes of name, address, agent or document recipient, deletion of goods or services, assignment, renewal, licence recordals and their early termination, correction of an entry, reissue of certificates, cancellation of the registration, and the withdrawal of any of those. The FAQ lists these as the business then available online and states that further types are announced separately.

What happens to an online account that is not used?

An account that is not used for three years is cancelled automatically. Doing business again after that requires a fresh registration. Keeping the email address and mobile number on the account current matters for the same reason: the office validates both when they are entered or changed, and uses them to notify the user when a document is served.

If I file online, will documents also arrive on paper?

No. Where a user has accepted the user agreement and submitted the application through the online system, the documents produced in that application are served electronically only. Applications submitted on paper continue to be served on paper. The same split applies to what comes next: after an electronic filing, the office does not accept paper versions of related materials, though it may require paper materials or physical evidence in a particular case.

When does an electronically served document count as delivered?

A trademark document is treated as served 15 days after the date it is sent to the online system. Periods that run from service, including the period for asking the office to review a refusal, are counted from that service date rather than from the day the document is downloaded or noticed. Documents are not despatched on non-working days, so a despatch made before a holiday period still starts the clock.

Official sources

Related reading

Filing in China, or bringing an existing file into the online system? Send us the mark and the goods list and we will confirm the steps and the fee before anything is submitted.

Last reviewed: 7 October 2026