Since 2025, significant changes have quietly taken place in the review rules and standards for "three-year non-use cancellation" (撤三) of trademarks in China.

Although CNIPA has not yet issued detailed official guidelines, the increasing number of supplementary notices received by trademark agents indicates that the evidence requirements for applicants are becoming stricter.

In the past, applicants only needed to provide preliminary investigation evidence—such as screenshots from major online platforms showing no trace of use—showing that the trademark had not been used for three consecutive years. The burden of proof largely fell on the trademark owner, who had to submit complete and genuine evidence of use.

Now, the requirements for preliminary evidence from the applicant have become much higher. Based on recent trends, applicants should provide initial investigation evidence including:

Business scope, operational status, existence status, and trademark registration details.

If the registrant is active, provide investigation reports and evidence related to product sales, service offerings, business premises, or office locations.

i. Comprehensive searches on general e-commerce platforms and industry-specific websites related to the goods/services of the trademark.

ii. Must include full-page screenshots of at least the first 5 consecutive pages from each platform.

iii. Searches must cover no fewer than 3 different platforms.