China’s Trademark Law Implementing Rules: Several Signals From Two Drafts

China's amended Trademark Law takes effect on 1 January 2027. On 28 September 2026, the China National Intellectual Property Administration (CNIPA) released for comment the Measures for Handling Trademark Matters under the Amended Trademark Law (the "Measures") and the Trademark Examination and Adjudication Guidelines (the "Guidelines"). The Supreme People's Court has separately circulated two draft judicial interpretations. A few points stand out.

1. Transition: old law for substance, new law for procedure

The Measures set out how filings spanning the two regimes are to be treated. Applications, oppositions and reviews filed before 2027 but decided after it will be handled under the new law. For marks registered before 2027, invalidation and cancellation proceedings will apply the old law to substantive questions. Opposition periods run from the date of preliminary publication, or for international registrations the WIPO publication date, with the new two-month period applying to