Nobody Reminds You When Your China Trademark Expires

Ten years from registration, then nothing. CNIPA does not send renewal reminders, the grace period closes on a fixed date with no extension, and the official fee is about USD 67 per class. Missing it costs the registration -- and from January 1, 2027 it also costs the twelve-month cushion that used to make a missed renewal survivable.

China does not send renewal reminders.

There is no notice, no warning email, no courtesy call. A Chinese trademark runs for ten years from the date it was registered. When that date passes without a renewal filing, the registration is cancelled, and the cancellation is published like any other administrative action -- in a database most foreign owners never open.

Every year this produces the same conversation. A brand owner discovers, usually by accident, that a mark they have held since 2017 lapsed months ago. Sometimes a competitor already filed for it. Sometimes the factory did. Sometimes nothing happened at all and the mark can still be rescued inside the grace period, for a fee that is 50 percent higher than doing it on time.

None of this is exotic. It is the most predictable failure mode in the entire China trademark system, and it is predictable for a structural reason that has nothing to do with the law: renewal is the one service in this industry that generates no new business. Nobody builds a client relationship by reminding you about a date.

Quick answer: A China trademark is valid for 10 years from the registration date (Article 43 of the 2026 revision). Renewal can be filed in the 12 months before expiry; after that a 6-month grace period opens with a 50 percent surcharge (Article 44). Miss the grace period and the registration is cancelled with no reinstatement route. The official fee is CNY 450 per class online, or CNY 675 per class if filed in the grace period -- about USD 67 and USD 101 at the October 2026 rate. Madrid designations of China renew on a different clock: WIPO opens the window only 6 months before expiry, not 12. And from January 1, 2027, a mark cancelled for non-renewal no longer gets the one-year bar that used to keep copycat filings out.

Ten Years Is a Long Time Until It Isn't

The term does not start when you file. It starts when CNIPA registers the mark, which under Article 32 is at the earliest nine months after filing, plus a two-month publication period -- so eleven months in the fastest case, and longer if an opposition is filed.

That gap between filing and registration is where renewals get missed.

An owner who remembers the filing date sets a reminder for that date plus ten. Take a mark filed in early 2016 and registered on March 15, 2017. It expires on March 14, 2027. The renewal window opened on March 15, 2026. The grace period closes on September 14, 2027. Three dates, all derived from one date most owners have never looked up.

An owner working from the 2016 filing date arrives in mid-2027 believing there is still time. The window closed in March. What is left is the grace period, which costs 50 percent more and closes in September. A reminder set a year late is not a reminder. It is a warning.

The arithmetic is not difficult. It is just done from the wrong starting point. Filing dates are in the client's own records. Registration dates are in CNIPA's register. Owners track what they own; the register tracks what the state granted, and only the second one controls the clock. China trademark timeline breaks down where each of these dates falls in a normal filing.

There is one more date that matters and almost never gets tracked: the date the registration certificate was actually issued. It is usually close to the registration date but not identical, and if the certificate was never collected, the owner may be working from an email rather than a document. In a renewal audit, the register is the only authority worth trusting.

Two Clocks, Not One

Two renewal systems touch China and they do not share a calendar.

A mark registered directly through CNIPA follows Article 44: the window opens twelve months before expiry. A mark that reached China as a Madrid designation follows the Madrid Protocol: WIPO opens the renewal window six months before expiry. Same ten-year term. Half the runway.

The six-month gap is the single most common cross-border mistake in this area, and it is invisible until it costs something. A company that renews its US, EU and UK portfolios off one docketing calendar will naturally apply a twelve-month lead time to China as well. For Madrid-routed marks that lead time does not exist. The window is already half gone by the time the internal reminder fires, and if the reminder is set at nine months -- a common default -- the filing arrives after the window has opened and closed.

WIPO's own fee structure for renewal is a basic fee of CHF 653, with CHF 100 for each designated member that has not declared an individual fee and CHF 100 for each class beyond the third. Filing during the grace period adds CHF 326.50, which is exactly half the basic fee. The surcharge percentage matches China's, but the currency and the filing venue do not. A Madrid renewal filed at CNIPA, or a CNIPA renewal filed at WIPO, does nothing at all -- and because neither office reports an error to the owner, the mark simply expires on schedule while everyone believes it was handled.

Portfolios assembled over a decade usually contain both kinds. The direct registrations are easy to find in a CNIPA owner search. The Madrid designations are in a WIPO record and often absent from the owner's own spreadsheet, because they were filed by a foreign associate in 2016 and nobody imported them. Madrid Protocol versus direct CNIPA filing covers the tradeoffs between the two routes; the point here is narrower and more urgent: they renew in different places, on different deadlines, at different prices.

The 2027 Wave

CNIPA's 2017 intellectual property protection white paper recorded 5.7482 million trademark applications that year, up 55.72 percent on 2016 -- the sixteenth consecutive year China led the world in filing volume. Examination was completed on 4.252 million marks, and 14.9198 million registrations were in force at year end.

Those numbers have a consequence that arrives on a schedule.

A mark examined and registered in 2017 carries a term ending in 2027. The 4.25 million marks that completed examination that year come due across 2027, and 2027 is also the year the revised Trademark Law takes effect. The two events are unrelated. They land in the same twelve months anyway.

Article 87 of the revision sets the commencement date at January 1, 2027, and adds a sentence that has been widely misread: trademarks already registered before this Law takes effect shall remain valid.

That sentence protects existing rights from being erased by the transition. It does not suspend the renewal obligation. A mark registered in 2015 still expires in 2025 or 2026 or whenever its ten years run out, and it still needs a renewal filing to survive. The transition clause answers a different question -- whether the new law retroactively invalidates old registrations -- and the answer is no. Owners who read it as a guarantee that old marks are grandfathered are reading a validity provision as an exemption, which it is not.

What the revision actually does to renewal is narrower than the wave of commentary suggests, and more consequential than the commentary noticed. Articles 43 and 44 carry over the existing rules almost verbatim. Ten-year term, twelve-month window, six-month grace, cancellation for non-renewal. The renewal machinery itself did not change. What changed is what happens after a mark dies, and it changed in a place nobody was looking.

The Safety Net Was Removed, and Almost Nobody Noticed

This is the part that has not been written about, because it sits in the wrong chapter of the statute.

Under the 2019 law, Article 50 read like this: where a registered trademark is cancelled, declared invalid, or not renewed upon expiry, the Trademark Office will not approve any application for an identical or similar mark on identical or similar goods for one year from the date of cancellation, invalidation or removal.

Three triggers. Cancellation, invalidation, non-renewal. All three created a one-year freeze. If your mark lapsed because the renewal was missed, nobody could register a copy of it for twelve months. You could not re-file it yourself during that year either -- but neither could anyone else. The brand sat in a locked room while you worked out what to do next.

Article 49 of the revision reads differently: where the trademark registrant applies to cancel its registered trademark, the Trademark Office will not approve an application for an identical or similar mark on identical or similar goods for one year from the date of the cancellation announcement.

One trigger. Voluntary cancellation. That is the entire list.

The one-year bar now applies only when the owner chooses to give the mark up. A mark that dies because a renewal was missed, because it was revoked for three years of non-use, or because it was invalidated no longer produces any blocking period at all. The day the cancellation is announced, the space is open.

Read the two provisions side by side and the practical effect is stark. Under the old law, a missed renewal cost you the registration but bought you twelve months of quiet. Under the new law, it buys you nothing. The next applicant can file the same day the cancellation publishes, CNIPA must accept the filing, and there is no legal ground to refuse it on the basis that the mark recently belonged to somebody else.

This is a change that favors anyone hunting for a dead brand to take. It is not a change that favors the owner who missed a date. And it lands in January 2027, in the same month that a decade's worth of 2017 registrations begin to come due.

The old cushion was never designed as a rescue window. It existed to prevent consumer confusion -- a mark that has just disappeared from the register should not be instantly re-registered by a stranger while the market still associates it with the previous owner. The revision narrows it to voluntary cancellations, on the logic that an owner who walks away has signaled abandonment and the market has been put on notice. That logic is defensible. The consequence for a foreign owner who simply forgot is that the system no longer builds in a pause.

Practitioners who handle these files describe the same sequence every time. The mark expires. The grace period closes. The owner notices four to ten months later, usually when a marketplace complaint or a customs hold forces them to prove they own the brand. The first question is always whether anything can be done.

Under the 2019 law the answer was sometimes yes, because the one-year bar meant the mark was still unclaimed and a fresh application had a clear field once the year ran. Under the revised law the field is not clear. Somebody may already be standing in it, and if they are, the conversation shifts from a renewal fee to an acquisition. CNIPA review suspension rules covers the related mechanism that lets an application be held while a blocking mark clears; it is useful protection, but it is not a substitute for filing on time.

One clarification worth stating plainly, because it circulates as a rumor in the other direction: the change does not mean an expired mark can be re-registered by its former owner on better terms. Article 49 removes a barrier for third parties. It does not restore anything to the owner who let the mark go.

What Renewal Actually Costs

CNIPA publishes its fees in renminbi. Converted at the late-October 2026 market rate of 6.681 CNY per USD and rounded to the nearest dollar, the renewal numbers look like this:

Two observations follow from that table, and both matter more than the totals.

The first is that a new application is cheaper than a renewal. CNY 270 against CNY 450. This is the number that makes owners hesitate, and it is the wrong number to focus on. A new application gets a new filing date, goes through examination again, publishes for opposition for two months, and can be refused. A renewal keeps the original registration date, which is the date that decides who wins against a later applicant. Saving CNY 180 per class to surrender priority is not a saving. China trademark registration cost sets out the full filing cost structure; the relevant comparison here is that renewal is the only path that preserves the date.

The second is that the change-of-address fee is zero online. That line is not a typo. CNIPA charges nothing to record a change of name or address if the filing goes through the online system. Which means the most common reason a renewal notice never arrives -- the registered address is an office the company vacated in 2021 -- is fixable for free, and almost nobody fixes it.

The grace period adds 50 percent, not 100 percent. A single-class mark renewed late costs CNY 675 instead of CNY 450, roughly USD 101 against USD 67. That is a rounding error against the cost of losing the registration. It is worth saying plainly because the opposite belief is common: owners treat the grace period as a penalty severe enough to justify walking away. It is not a penalty. It is the last cheap option, and it closes on a fixed date with no extension.

Compare it with the alternative. Recovering a mark that a third party has already registered in China -- through negotiation, assignment, or invalidation -- is a five-figure exercise in most cases, measured in months and frequently in years. Buying back a trademark from a China squatter documents what that negotiation actually looks like. The gap between USD 101 and that outcome is the entire argument for a renewal calendar.

Renewal Cannot Fix Anything

Renewal is a maintenance act, not an editing act. The revised law draws that line in three places, and owners cross it constantly.

Article 28: a registered trademark whose sign needs to change must be filed as a new application. Not amended. Filed again, with a new date.

Article 27: a registered trademark that needs protection on goods outside the approved scope must be filed as a new application. Adding a class during renewal is not a thing that exists.

Article 45: a change to the registrant's name, address, or other registered particulars requires a separate application to record the change. It is not bundled into renewal, and it does not happen automatically because a renewal was filed.

Practitioners see the same three requests attached to renewal instructions. "While you are at it, add class 35." "While you are at it, update the address." "While you are at it, the logo was redesigned slightly."

The first two are separate filings that can run in parallel with the renewal and should. The third is a new application on a new ten-year clock, and if the redesign is more than a trivial cleanup it may also open a gap in protection between the old mark and the new one. That gap is where a competitor files. China trademark assignment and transfer covers the related mechanics for moving a mark between entities, which is the other thing owners try to fold into a renewal.

The one thing renewal genuinely cannot do is buy back time. A renewal filed in 2026 carries the registration through 2036. It does not retroactively cover a gap that opened in 2024 because the address was wrong and a CNIPA notification went to a building that no longer exists.

The Foreign-Owner Rule

Article 11 of the revised law, second paragraph: a foreigner, foreign enterprise, or other foreign organization without habitual residence or a business office in China that applies for trademark registration or handles other trademark matters in China shall entrust a legally established trademark agency.

"Other trademark matters" includes renewal. A foreign owner cannot log into CNIPA's online system and file the renewal personally, the way they can at the USPTO or EUIPO. The filing has to pass through a Chinese agency. The owner's renewal timeline runs through an intermediary by law, not by choice.

Article 10 of the same law confirms the general rule that applicants may handle matters themselves or through an agency. Article 11 carves out the exception for foreign applicants without a China presence. The two provisions are read together so routinely in Chinese practice that they are sometimes quoted as one.

Implementation Regulation Article 5 adds a detail that matters more than it looks. When a foreign applicant files, it must designate a recipient within China to receive subsequent legal documents. That recipient is the notification channel. If the person named in 2018 has left the company, retired, or moved to another firm, the channel is broken, and nothing in the system will flag it. The renewal reminder, if anyone sends one at all, lands in a mailbox nobody reads.

This is why the failure is so quiet. There is no moment where a system reports an error. There is only a date that passes.

A Renewal Audit in Seven Steps

None of the seven steps below requires a legal judgment. All of them require somebody to actually open the register.

1. List every China registration, including Madrid designations. A Madrid designation of China is a China registration for enforcement purposes and a WIPO record for renewal purposes. Portfolios assembled over a decade usually contain both, and the second kind gets missed because it does not appear where the owner expects it to.
2. Write down the registration date, not the filing date. Expiry is registration date plus ten years, minus one day. If the certificate is not on hand, the CNIPA register shows it.
3. Check the registered name and address against the current entity. If the registrant is a subsidiary that was merged away, or an address the company vacated, the record needs a change filing before or alongside renewal. Online change filings cost nothing.
4. Count the classes. The fee is per class. A mark registered across four classes costs four times a single-class renewal. Budgeting for one and discovering four is a recurring surprise, and it usually surfaces two weeks before the deadline.
5. Confirm the China recipient is still a live contact. Regulation Article 5 makes that designation the legal notification channel. A stale name there is worse than no name, because it looks like coverage.
6. Separate the two routes. Direct CNIPA registrations renew at CNIPA. Madrid designations renew at WIPO. They are not interchangeable, and a renewal filed in the wrong venue produces no result and no error message.
7. Set the alarm from the earlier deadline. For Madrid-routed marks that is six months before expiry, which means the internal reminder needs to fire at least eight months out. For direct filings, twelve months before expiry with a reminder at fourteen.

Run the audit once and the output is a table with three columns: registration number, expiry date, renewal venue. That table is the whole project. Everything else is execution. China trademark basics for foreign brands covers the underlying registration concepts if any of the terminology above is unfamiliar.

Renewal Is Not the Same as Safety

Renewing preserves the registration. It does not preserve the mark's usefulness, and the two get conflated constantly.

Article 57 of the revised law allows any person to apply to cancel a registered trademark that has become the generic name of the goods it covers, or that has not been used for three consecutive years without justification. A renewed mark that has sat unused since 2019 is exactly as cancellable in 2028 as it was in 2026. Renewal changes nothing about that exposure.

Article 78 addresses a different consequence. In an infringement action, if the proprietor cannot prove actual use of the mark during the three years before the infringing conduct, and cannot prove other losses caused by the infringement, the accused infringer bears no liability for damages. The registration survives. The damages claim does not.

That produces an uncomfortable conclusion for owners who treat the register as an asset vault. A renewal certificate is evidence that a right exists, not evidence that the right is worth anything. The enforcement value comes from use records -- dated invoices, packaging, advertising, platform listings -- maintained across the term. China trademark non-use cancellation sets out what CNIPA accepts as evidence of use, and the standard is more demanding than most owners assume.

A renewal filed on time protects the registration. It does not protect a brand that stopped existing in the market three years earlier.

The Practitioner's View

Three things about renewal that experienced Chinese practitioners say to each other and rarely write down.

The first is that renewal is the only trademark service with no commercial engine behind it. Filing generates fees. Opposition generates fees. Invalidation generates fees. Renewal generates a small fee once a decade, and the client relationship that would justify chasing it usually belongs to whoever filed the original application -- possibly a different firm, in a different decade, with different staff. Nobody's business model depends on your renewal calendar. That is the structural reason renewals get missed, and no amount of software fixes a misaligned incentive. The fix has to be internal: a calendar the owner controls, checked against the register rather than against an old invoice.

The second is that the 2027 change to the one-year bar will take about three years to show up in the data. Cancellations publish quietly. The owner who lost a mark in 2027 typically finds out in 2029, when they try to enforce it and discover they no longer own it. By then the copy is registered, has its own examination history, and has probably been used in the market. The cost of recovery has moved from CNY 675 to a negotiation, and the negotiation starts from a position where the other side holds a valid registration.

The third is that the cheapest intervention in this entire area is a change-of-address filing that costs nothing. Portfolios do not usually fail because of a legal problem. They fail because a letter went to an address that stopped existing.

There is a fourth observation that is less comfortable. Renewal is also the place where bad agency practice does the most damage, because it is invisible for ten years and then irreversible in a single day. An owner who paid for a "renewal service" in 2023 and received a PDF has no way of knowing whether a filing was made unless they check the register. The register is public. Checking it costs nothing and takes minutes.

Frequently Asked Questions

How long is a China trademark valid?

Ten years from the date of registration, under Article 43 of the revised Trademark Law. The clock starts on the registration date recorded by CNIPA, not the filing date, and the two can be more than a year apart.

When can a China trademark be renewed?

Within the twelve months before expiry, under Article 44. A six-month grace period follows with a 50 percent surcharge. If neither window is used, the registration is cancelled.

What happens if the twelve-month window is missed?

The mark can still be renewed during the six-month grace period for an additional CNY 225 per class online, on top of the CNY 450 renewal fee -- CNY 675 total, roughly USD 101 per class at the October 2026 rate.

What happens if the grace period is missed?

The registration is cancelled. Article 44 sets out no reinstatement procedure, and Chinese practice offers none for marks cancelled for non-renewal. The practical options are a new application with a new filing date, or recovering the mark from whoever registered it next.

Can an expired China trademark be renewed?

No. Once the grace period closes the registration is gone. What can be filed is a new application, which starts examination from zero and carries a later priority date -- the opposite of what a renewal preserves.

How much does China trademark renewal cost?

CNY 450 per class filed online, or CNY 500 on paper. The grace-period surcharge is CNY 225 online or CNY 250 on paper. At 6.681 CNY per USD these are about USD 67, USD 75, USD 34 and USD 37 per class. Agency fees are separate and are not set by CNIPA.

Does the 2027 Trademark Law change the renewal rules?

Not the renewal rules themselves. Articles 43 and 44 carry over the same ten-year term, twelve-month window, six-month grace period and cancellation for non-renewal. What changed is Article 49, which narrows the one-year bar on copycat filings to voluntary cancellations only -- so a mark cancelled for non-renewal no longer enjoys a twelve-month protected gap.

Can a foreign company renew a China trademark without an agent?

No. Article 11 requires foreign applicants without habitual residence or a business office in China to entrust a Chinese trademark agency for registration and other trademark matters, which includes renewal.

Is renewal automatic?

No. CNIPA does not renew marks on its own initiative and is not obligated to notify the owner before expiry. The filing has to be made, by someone, on time.

What if the registered address has changed?

File a change of address under Article 45. Online filings carry no official fee. Doing it before the renewal window opens keeps the notification channel intact.

Do Madrid designations renew on the same schedule?

No. WIPO opens the renewal window six months before expiry, half the Chinese domestic window. The grace period is also six months, with a 50 percent addition to the basic fee -- CHF 326.50 on top of CHF 653.

The Bottom Line

Renewal is the least interesting part of owning a China trademark and the part most likely to end it.

The filing costs about USD 67 per class. Missing it costs the registration, and from January 1, 2027 it also costs the twelve-month gap that used to give an owner room to recover. That second loss is the one nobody has priced in, because it sits in Article 49 rather than in the renewal chapter, and because its effect only becomes visible when someone else files for your brand.

The audit takes an afternoon. The register is public. The dates are arithmetic.

Sources:

• Trademark Law of the People's Republic of China (2026 Revision) -- CNIPA official text, adopted June 26, 2026, effective January 1, 2027 (Articles 10, 11, 27, 28, 43, 44, 45, 49, 57, 78, 87)
• CNIPA Trademark Fee Guide -- official fee standards, updated October 9, 2026
• WIPO Madrid System -- renewal of an international registration: window, basic fee and grace-period surcharge
• CNIPA -- 2017 China Intellectual Property Protection Status: trademark filing and registration statistics
• Trademark Law Implementing Regulations -- Article 5, designation of a recipient within China