Checked: 2 November 2026 (official source pages); check updates before publication.
Direct answer
Keep dated, verifiable records connecting the registered mark to the approved goods or services and to real commercial activity; a folder of undated screenshots is not enough for a reliable review.
Work backwards from the registration
The evidence plan starts with the mark as registered, the named owner, the approved goods or services and the relevant period. Use may occur through a distributor or licensee, but the relationship and the use should be documented rather than assumed. Capture the mark on products, packaging, transaction documents and advertising in a way that shows context and date. Preserve original files and source URLs where possible; a cropped image can lose the facts needed to evaluate it.
Why a routine archive matters
Under Article 49 of the 2019 Trademark Law, a registered mark can be challenged for three consecutive years of non-use without a valid reason. The enacted 2026 revision, effective 1 January 2027, has a corresponding rule in Article 57. Whether a particular item proves trademark use depends on the mark, goods, time and transaction. This guide does not promise that one invoice, export declaration or marketplace screenshot will defeat a challenge.
Make records retrievable
A practical archive can pair each invoice with the product listing or packaging used in the same transaction. Save distributor and licence agreements, proof of the parties’ identity and evidence of the licensee’s authorized activity. Keep a chronology of product launches, sales channels and market changes. Before relying on export-only or offshore activity, ask a China professional how the evidence applies to the registered mark and designated goods. Review the archive periodically while records can still be obtained from partners. ## Questions to resolve before action
- Does the evidence show the exact registered mark?
- Can the goods or services be identified?
- Is the record dated and attributable to the owner or authorized user?
- Can original documents be retrieved if challenged?
Official sources and scope
- https://www.cnipa.gov.cn/art/2019/7/30/art_95_28179.html
- https://www.cnipa.gov.cn/art/2026/6/26/art_3686_206940.html
- https://www.cnipa.gov.cn/art/2025/5/30/art_55_199891.html
As checked on 2 November 2026, the 2019-amended Trademark Law is the current law. The revised law was adopted on 26 June 2026 and is scheduled to take effect on 1 January 2027 (Article 87). A consultation draft is not an operative rule. Confirm the governing text and any final implementation or transition measure for the date of the specific matter. This article is ChanYond’s independent reading aid, not a CNIPA statement or case-specific legal advice.