The trademarks on packaging boxes, leaflets, and product labels are printed by printing enterprises. This means the printing stage has its own compliance obligations: the printer must verify that the client has the right, the trademark owner must prepare the supporting documents, and if both sides slip, they may be penalized or even found to infringe.
1. Who Blocks You at Which Stage
- Scope of printed materials: Article 2 of the Regulations on Printing Administration defines "packaging and decoration printed materials" as including trademark identifiers, advertising materials, and paper, metal, plastic, etc. used as product packaging and decoration. In other words, printing a LOGO-bearing box falls under this regulation.
- Operating license: the state operates a printing business licensing system; publication printing is licensed by the provincial publishing authority, and packaging/decoration printing and other printing by the municipal publishing authority of a districted city; the publishing authority shall decide approval or rejection within 60 days of receiving the application. Individuals may not engage in the printing of publications or packaging/decoration printed materials.
- Publications have separate rules: publishing units may not entrust publications to units without a publication printing or reproduction license; publications must be published by a qualified publishing unit — a company "publishing" and printing materials for distribution on its own is a violation.
2. What the Client Must Prepare: Per the Measures for the Administration of Trademark Printing
The current Measures for the Administration of Trademark Printing have been in effect since September 1, 2004, and were amended several times (most recently by SAM Order No. 31 of 2020, the third amendment). Key provisions:
- Article 3: a trademark printing client shall present a copy of its business license or a lawful business certificate or identity proof.
- Article 4: to print a registered trademark, the client shall present the Trademark Registration Certificate and additionally provide one copy; a licensee using another's registered trademark under a trademark use license contract who needs to print the trademark shall also present the license contract text and provide one copy; where the registrant separately authorizes the licensee to print the trademark, the authorization letter shall also be presented with one copy.
- Article 5: the printed trademark artwork must be identical to the trademark image on the Registration Certificate; where a licensee prints the trademark, there must be an explicit authorization letter or the contract must contain licensing content; the licensee's trademark artwork must indicate the licensee's company name and address, and use of the registration symbol must comply with the Implementing Regulation of the Trademark Law.
- Article 6: for printing an unregistered trademark, the artwork must not violate Article 10 of the Trademark Law, and must not be labeled "registered trademark" or bear the registration symbol.
- Article 7: the printing unit shall verify the supporting documents and the trademark artwork; where the documents specified in Articles 3 and 4 are not provided, or the requested trademark identifier does not comply with Articles 5 and 6, the job may not be accepted.
3. What the Printing Enterprise Must Do: Five Systems and Two-Year Retention
- Five systems: Article 5 of the Regulations on Printing Administration requires printing operators to establish a job-acceptance verification system, job-acceptance registration system, printed materials custody system, printed materials delivery system, and destruction system for defective products in printing activities.
- Job registration and retention: the printing unit shall fill in the Trademark Printing Business Registration Form; when identifier printing is completed, sample identifiers shall be extracted within 15 days and archived together with the registration form, a copy of the Trademark Registration Certificate, copies of trademark use license contracts, and copies of authorization letters; the records and ledgers must be kept for 2 years.
- Warehousing and destruction: establish trademark identifier warehousing in/out systems and registration ledgers; defective identifiers must be centrally destroyed and must not flow into society.
- Verification obligations at the regulation level: the penalty provisions of the Regulations on Printing Administration make clear that accepting a job to print registered trademark identifiers without verifying and checking, per the regulation, the copy of the Trademark Registration Certificate bearing the seal of the administrative department for industry and commerce (now the market regulation department), the registered trademark artwork, or copies of registered trademark use license contracts constitutes a violation; the same applies to accepting jobs to print advertising materials or printed materials used as product packaging without verifying the client's business license or the individual's resident ID. A printing enterprise accepting a job to print registered trademark identifiers shall verify the copy of the Trademark Registration Certificate bearing the seal of the county-level market regulation department where the registrant is located and check the registered trademark artwork; where accepting a job from a registered trademark licensee, it shall also verify the trademark use license contract, and keep the above materials for 2 years.
4. Penalties and Risks
- Article 11 of the Measures for the Administration of Trademark Printing: violating Articles 7 through 10, the violator is ordered to correct within a time limit and given a warning, and fined up to three times the illegal gains, capped at RMB 30,000; where there are no illegal gains, a fine of up to RMB 10,000 may be imposed.
- Article 13: accepting jobs in violation of Article 7 where the printed trademark is identical or similar to another's registered trademark constitutes trademark infringement and will be handled as trademark infringement — no longer a matter of fine-level penalties.
- For the client: having an unlicensed printer print your packaging may not only get you investigated but also leave you without a compliance chain when facing market-regulation spot checks and platform qualification verification.
5. Common Pitfalls and Practical Recommendations
- Marking ® on an unregistered trademark: the artwork carries the registration symbol but no certificate can be produced — an expressly prohibited situation, and the printer has a duty to refuse the job.
- Outdated certificate information: the trademark underwent change, renewal, or assignment but only the old certificate is provided. Per Article 15 of the Measures, the "Trademark Registration Certificate" includes the change, renewal, and assignment certificates issued by the CNIPA, which must be provided together.
- Licensee printing without company name and address: an express requirement of Article 5, easily missed.
- Unclear authorization scope: the trademark use license contract does not state whether it covers "printing trademark identifiers," leaving the licensee's printing at risk of exceeding scope.
- Artwork "beautified": changing fonts, proportions, or adding pinyin to the registered image during printing makes the artwork inconsistent with the certificate — non-compliant printing.
- Treating publications as "printed materials": books, periodicals, and internal reference publications each have their own licensing paths; printing publications under a packaging printing license is a mismatch.
- Casual handling of defective products: trademark-bearing defective identifiers flowing out is both a brand risk of your own and may constitute contributory infringement.
Practical recommendations
- Build a "trademark printing materials package": the registration certificate and change/renewal/assignment proofs, business license copy, license contract or authorization letter (including printing authorization clauses), scanned and archived, sent directly to the printer with each order;
- Add a sentence to license contracts: in trademark use license contracts, state expressly that the licensee "has the right to print trademark identifiers for production, packaging, and promotional purposes";
- Check the printer's license first: confirm it holds a valid printing business license and understand whether its verification and archiving systems are in place;
- Both parties sign off on artwork samples: keep samples based on the certificate image to avoid batch-to-batch differences;
- Publications go through proper publishing channels: books, periodicals, series, and internal materials are handled under publication administration rules; for trademark classes, publications usually correspond to Class 16, and product packaging to the actual goods classes.
6. Summary
Trademark compliance in the printing stage boils down to one sentence: for registered trademarks, you must be able to produce the registration certificate and the license chain; for unregistered trademarks, no registration labeling is allowed. A printer is not a workshop that "prints whatever comes in" — its verification and archiving obligations are an external line of defense for the brand owner's risk control. The rules cited in this guide are current as of 2026; defer to the latest requirements of the publishing and market regulation authorities.
7. Where to Get It Done
If you need agency for the above procedures, book a licensed trademark agent's license filing service with MyTMBee, with full assistance from material preparation through submission and follow-up.