By Eileen Hui
In a significant procedural shift, the China National Intellectual Property Administration (CNIPA) has officially confirmed in its Q&A module on Oct. 27, 2025 that the Trademark Office will no longer send copies of certain official responding notifications to trademark agencies.
This adjustment was confirmed again by CNIPA on October 30, 2025, in response to another inquiry.
From now on, notification related to cancellations, oppositions, and invalidations requiring the rights holder’s response will be sent directly to the contact address of the trademark owner only, rather than to both the owner and its agency representative.
This marks a major departure from the practice in the past, under which the Trademark Office delivered paper documents to the registrant and simultaneously issued copies to agency who filed the application and also the last-appointed agency handling the relevant trademark matter. That dual system had allowed agencies to assist clients in monitoring deadlines and ensuring timely responses to CNIPA notifications.
From “Agency Copy” to “Owner Responsibility”
Under the new rule, only the rights holder will receive official correspondence by registered mail, and no copy will be transmitted to the agency. This procedural change shifts the responsibility for monitoring, receiving, and responding to CNIPA correspondences quarely onto the trademark owner.
While this reform simplifies the CNIPA’s communication process, it introduces new risks for brand owners, particularly foreign companies, who may have registered addresses that are outdated, inactive, or used only for administrative purposes. If such an address fails to receive a notice, the owner could miss critical deadlines to respond to cancellation or invalidation actions, potentially resulting in the loss of trademark rights by default.
Key Implications and Risks
Two primary risks arise under the new framework:
1. Invalid or outdated addresses – Notices will now be sent exclusively to the right holder’s contact address on file. If the trademark owner has moved or uses a virtual or shared address, official letters may go undelivered. Missing a response deadline can lead to the trademark being cancelled or invalidated.
2. Reduced agency oversight – Many owners rely on their appointed trademark agencies to monitor filings and defend against challenges. Without the copy delivery mechanism, agencies will no longer be automatically informed of CNIPA actions unless the rights holder forwards the notice themselves.
Practical Steps for Trademark Owners
To mitigate these risks, experts recommend that trademark owners:
Verify and update the contacting addresses through CNIPA’s online service system to ensure accurate delivery.
Implement regular monitoring of trademark statuses via the official CNIPA trademark database or engage professional monitoring services with clear reporting terms.
Use postal forwarding or pickup services, allowing important mail from CNIPA to be redirected or held for collection.
A Shift Toward “Owner Accountability”
This reform reflects CNIPA’s broader policy goal of placing greater responsibility on rights holders to actively manage and safeguard their intellectual property. While this approach encourages more direct engagement by trademark owners, it also demands stronger internal compliance and communication mechanisms to prevent unintentional loss of rights.
The change has been confirmed through CNIPA responses, signaling full implementation of the new delivery system for all cases requiring rights holders to submit defenses or evidence.