When a company applies for numbers such as 400 or 95/96, it submits proof of entity qualification, not a trademark certificate. But once the number goes live, the brand name read out in your call handling, the brand abbreviation in your SMS signature, and the LOGO on your caller ID card all constitute trademark use in the sense of the Trademark Law. The number is only a channel; what you really need to confirm ownership of in advance is the "name" that keeps appearing in that channel.
1. The Relationship Between Number Applications and Trademarks
Enterprise communication numbers are national numbering resources. The application stage reviews entity qualifications and intended use, not trademarks:
- Numbers starting with 95/96: numbering resources planned and managed by the Ministry of Industry and Information Technology (MIIT). Applicants generally need the corresponding value-added telecommunications business license; specific conditions, materials, and procedures follow the requirements published on the MIIT government service platform.
- Numbers starting with 400: handled through basic telecom operators or their authorized service providers, each of which has its own materials checklist; specifics follow the requirements published by the operators and service providers.
- SMS numbers in the 106 range: enterprise SMS numbering resources under unified planning and management, applied for under the company's real name; the SMS signature (sender name) must correspond to the entity or an authorized brand.
The conclusion is clear: no regulation lists a trademark certificate as a required material for number applications. But that does not mean trademarks are irrelevant — they determine whether you can legally use a brand name to reach customers after the number goes live.
2. Three Types of Trademark Use After a Number Goes Live
Article 48 of the Trademark Law defines "use of a trademark" as applying a trademark to goods, packaging or containers, transaction documents, or to advertising, exhibitions, and other commercial activities to identify the source of goods. In communications scenarios, at least three touchpoints fall within this definition:
- Voice announcements: an agent's opening line such as "Hello, this is the ×× brand customer service" is the most typical use, identifying the source of services to the general public.
- SMS signatures and content: the signature field of marketing or notification SMS is usually the company abbreviation or trademark, and brand and campaign names in the message body are likewise commercial promotion.
- Caller ID cards / outbound display names and icons: carrier or third-party enterprise card services display the company name and LOGO, a direct commercial display of brand identifiers.
What these three have in common: they are all outward-facing uses that identify source, and therefore must be used with proper rights.
3. Brand Exposure Must Be "Authorized Use"
- Ownership check: where the number user differs from the trademark registrant (franchisees, agents, distributors, or outsourced operators), a trademark use license must be obtained first.
- Get the license scope right: the license agreement should specify the licensed trademarks, classes of goods/services, territory, term, and whether it covers uses such as "telemarketing, customer service, and SMS notifications." Many older agreements only say "sales," and outbound calling is then deemed use beyond the licensed scope.
- Typical pitfall: a franchisee continues to use the original 400 number and enterprise caller ID card to announce the brand after the license expires — this constitutes infringement under Article 57 of the Trademark Law and may also expose the franchisee to breach-of-contract liability.
- The reverse case: an unauthorized party using another's brand name in SMS or calls to create a confusing "official customer service" effect is one of the most common types of trademark infringement in communications scenarios. Real-name registration of numbers means rights holders can easily trace the actual user.
4. Compliance Changes in Number Protection (Privacy Number) Scenarios
The "intermediate numbers" and "privacy numbers" used extensively by express delivery, food delivery, and ride-hailing platforms gained a dedicated regulatory framework starting in 2025. MIIT's Notice on Launching the Number Protection Service Pilot (工信部信管函〔2025〕130号, June 2025) clarifies:
- Number protection services are provided jointly by the application platform provider, the basic platform provider, and the business user;
- A dedicated number range (the 700 range) is planned as the dedicated numbering resource for number protection services;
- Threshold requirements apply to the application platform provider's entity, including a minimum registered capital of RMB 10 million for nationally or cross-provincially operating providers.
For brand owners, this means that when you use privacy numbers on platforms for after-sales service or follow-up calls, the number itself is provided by a licensed entity, but you remain responsible for the brand identifiers in scripts and SMS messages — using a "compliant channel" does not exempt trademark use.
5. Practical Recommendations
- Verify ownership before going live: before activating a number, confirm who owns the trademark for the brand name and whether the license chain covers communications scenarios, so you don't have to retrofit authorization after launch.
- List communications uses separately in the license: explicitly include outbound calls, customer service, SMS notifications, and caller ID card display in the trademark license agreement.
- Keep a number-brand ledger: record which brand, license basis, and license expiry date each number corresponds to, and renew or change scripts before expiry.
- Signal identifier compliance: do not use confusing expressions such as "official" or "authorized center" in SMS signatures or cards; even with authorization, such wording often gets flagged as a violation by platforms.
- Manage the channel side: outsourced operators and call-center vendors are the most likely link to overstep brand rights — contracts should state the permitted scope, prohibit sub-licensing, and set out breach consequences.
6. Summary
Number applications look at qualifications; number use looks at trademarks: the former determines whether you can activate, the latter whether you can legally announce the name afterward. Solidify the "ownership — authorization — ledger" chain, and communications scenarios won't become a blind spot for trademark risk. The rules cited in this guide are current as of 2026; always follow the latest requirements of the competent authorities and carriers.