← All free toolsHuaqing IP · CNIPA-recorded agency

China Opposition Deadline: 3 months or 2 months?

China shortened the trademark opposition period from three months to two months. The switch is keyed to the preliminary-approval publication date, not the filing date. Enter that date to get the exact deadline.
Today
31 Dec 2026 (last 3-month day)
1 Jan 2027 (first 2-month day)

Why the date matters more than the calendar

Until 31 Dec 2026
3-month window (2019 Law)

Marks published for opposition before 1 January 2027 keep the three-month period under the law then in force.

26 Jun 2026
Revised Trademark Law passed

NPC Standing Committee adopts the revision (Chairman's Order No. 77). Article 36 sets the opposition period at two months from publication.

1 Jan 2027
2-month window (new Law)

Marks published on or after this date carry the two-month window. Opponents lose one month to watch, gather evidence and file.

What to do with the deadline

If the window is open

File through a CNIPA-recorded agent. The official opposition fee is CNY 450 for an e-filing (CNY 500 on paper); foreign opponents must act through an agent. Evidence of earlier rights and confusing similarity is the core of the filing.

If the window has closed

Opposition is no longer available. For a registered mark the route is invalidation (official review fee CNY 675 e-filing) or non-use cancellation after three years; both are slower and costlier than opposing in time.

If publication falls in late 2026

A mark published in October–December 2026 still carries three months. Do not assume the shorter window already applies — check the publication date, not the current date.

If it is a Madrid international registration

For an IR designating China, the relevant publication is the WIPO record of the international registration; the draft transition rules key the window to the WIPO publication date. Confirm both the WIPO date and the CNIPA gazette entry before filing.

Frequently asked

Is the two-month opposition period already in force?

No. The revised Trademark Law takes effect on 1 January 2027. Until then the three-month period applies. The two-month rule applies to marks published for preliminary approval on or after 1 January 2027.

Which law applies to a mark published in December 2026?

The 2019 Law: three months from publication. Under the draft Supreme People's Court temporal-application rules, the governing date is the preliminary-approval publication date. The transition instruments are still draft, so confirm before relying on a borderline date.

Does the change affect invalidation or refusal review deadlines?

No. This calculator covers the opposition window only. Refusal review remains 15 days from receipt of the refusal notice, and invalidation has its own grounds and time limits.

Can I still oppose after the mark registers?

No. Once the opposition window closes and the mark registers, opposition is unavailable; the routes are invalidation, non-use cancellation (after three years of non-use) or negotiation. That is why watching publications matters.

Need the deadline checked against the official gazette?

We monitor CNIPA publications for foreign brand owners and file oppositions through a recorded agent. Send the publication number or a screenshot of the gazette entry.

Book a 30-min check Check your grounds →
Sources: Trademark Law of the PRC (2026 revision), adopted 26 June 2026, effective 1 January 2027 — Art. 36 (two months from publication); NPC Standing Committee explanatory note (opposition period cut from three to two months); CNIPA fee schedule (opposition CNY 450 e-filing, review CNY 675 e-filing). Transition treatment follows the draft SPC temporal-application provisions published 14 September 2026 and remains subject to the final text. This page is general information, not legal advice.