Successful advertising in China is more complex than just localising your ad content and creatives. A campaign that passes a brand’s global review may still be rejected by a Chinese platform because it uses an unsupported superlative, lacks a local product approval, disguises sponsored content as a review, or directs users to a landing page that does not match the approved advertisement.
This guide explains how foreign companies can structure, review, launch, and monitor compliant advertising campaigns in Mainland China.
The main national law is the Advertising Law of the People’s Republic of China. It applies to commercial advertising activities in mainland China where a business directly or indirectly promotes its goods or services through a medium or format.
Digital campaigns are also governed by the Measures for the Administration of Internet Advertising, effective since 1 May 2023. The measures cover advertising delivered through websites, webpages, apps, mini-programs, social media, search results, livestreams, smart devices, and other internet media.
Depending on the campaign, other rules may apply, including:
Market-regulation authorities enforce the Advertising Law. Cyberspace, telecommunications, health, financial, drug, broadcasting, education, and other regulators may also become involved where a campaign raises issues within their jurisdiction.
In April 2026, the State Administration for Market Regulation, or SAMR, made clear that its current internet advertising enforcement priorities include paid traffic, precision targeting, livestream commerce, embedded advertising, AI-generated advertising, medical products, financial services, and education.
The advertiser is responsible for the truthfulness of its advertising. Appointing a Chinese agency, distributor, platform, or influencer does not transfer that core responsibility.
Other campaign participants have their own duties:
| Typical responsibility | |
| Advertiser | Product legality, licences, claim substantiation, approvals, creative content, landing pages, and instructions to suppliers |
| Advertising agency or operator | Client verification, document review, content checking, campaign records, and compliant design or placement |
| Media owner or advertising publisher | Advertiser and qualification checks, content review, ad identification, publication controls, and records |
| Internet platform | User identification, monitoring, complaint handling, preservation of evidence, and action against known or suspected illegal ads |
| KOL, celebrity, or livestream host | Duties may arise as an ad operator, publisher, or spokesperson depending on the activity |
| Distributor or China partner | Responsibility for claims and campaigns it creates or authorizes, plus contractual obligations to the brand |
Responsibility can overlap. A company posting advertisements through its own website, official account, app, or online store may be both advertiser and publisher. Under the Internet Advertising Measures, an advertiser that self-publishes must maintain and update an advertising archive for at least three years after publication ends.
Foreign brands should define approval authority and responsibility in writing. Contracts should cover who may create claims, modify creative, appoint influencers, select targeting, change landing pages, retain evidence, respond to complaints, and suspend a campaign.
There is no single rule requiring every foreign advertiser to establish a Chinese company. The practical answer depends on the advertising platform, product, payment arrangement, target users, landing page, industry, and local operating model.
Chinese media platforms commonly require a verified advertiser and may request:
Some platforms and campaign types accept overseas advertisers; others require a mainland entity or authorized local account holder. Platform onboarding rules can be stricter than the legal minimum and can change without a legislative amendment.
Before choosing a route, the foreign brand should decide who is legally selling the product, who is named as the advertiser, who owns the media account, who pays for the campaign, who operates the landing page, and who handles Chinese consumers. These roles should not contradict one another.
A strong onboarding package normally contains:
Names must match across the evidence. A common blocker is an advertiser account held by one entity, a landing page operated by another, a trademark owned by a third, and a product licence issued to a fourth, with no clear authorization chain connecting them.
Platform approval is not the same as legal approval. Even after a platform accepts the account and creative, the advertiser remains responsible for compliance.
China’s Advertising Law requires advertising to be true, lawful, clear, and not misleading. It also contains content restrictions that go beyond ordinary claim substantiation.
Advertising must not:
Foreign creative should also be reviewed for maps, flags, territorial descriptions, political or historical references, religious elements, cultural symbols, and Chinese-language wordplay. A visual that appears neutral in another market may be sensitive in China.
China’s prohibition on absolute language does not mean every superlative is automatically illegal in every context. SAMR has issued enforcement guidance recognizing context-specific exceptions. However, promotional claims such as “No. 1,” “the only,” “world-leading,” “100%,” “perfect,” or “the safest” remain high risk unless their use falls clearly outside the prohibition and the advertiser has reliable evidence. The safer approach is to use precise, verifiable statements.
Every objective claim should have evidence before publication—not after a complaint arrives.
Claims about a product’s function, performance, origin, quality, ingredients, price, manufacturer, validity period, sales, awards, or results must accurately reflect the product sold in China. Service descriptions, prices, provider details, quality promises, and promotional commitments must also be accurate and clear.
Where an advertisement uses data, statistics, research, survey results, quotations, or extracts, the information must be true and accurate and must identify its source. Any applicable scope and validity period should be disclosed.
The claim file should establish:
Global market-share data may not support a claim about China. Laboratory performance may not support a real-world outcome. A foreign certification may not be recognized as a Chinese product approval. Small-print qualifications also cannot cure a large headline that creates an overall misleading impression—an area identified for enforcement attention in SAMR’s 2026 advertising work priorities.
Comparisons should use equivalent products, time periods, methods, and conditions. They must not misrepresent a competitor or degrade another operator’s goods or services.
Certain advertisements require government review before publication. Under the Advertising Law and Internet Advertising Measures, this includes medical services, medicines, medical devices, pesticides, veterinary medicines, health foods, and special medical-purpose formula foods, as well as other categories specified by law.
Key sector risks include:
| Sector | Important advertising restrictions |
| Medical services, medicines, and medical devices | Prior review generally required; no guarantees of efficacy or safety, cure or effectiveness rates, improper comparisons, or spokesperson endorsements |
| Prescription medicines | Internet advertising is prohibited except where another law or regulation provides otherwise; under the Advertising Law, promotion is generally limited to designated medical and pharmaceutical publications |
| Health foods | Prior review required; no disease-prevention or treatment claims, health guarantees, necessity claims, or spokesperson endorsements; required warning language must be shown |
| Ordinary foods and supplements | Must not claim disease treatment or use medical language; ordinary food cannot be promoted as if it were a medicine or approved health food |
| Special medical-purpose formula foods | Prior advertising review and category-specific statements may be required |
| Cosmetics and beauty products | Claims must match product classification, registration or filing, and substantiation; medical or disease-treatment claims are prohibited for ordinary cosmetics |
| Tobacco and e-cigarettes | Internet advertising is prohibited, and tobacco advertising is heavily restricted across other media |
| Alcohol | Must not encourage excessive drinking, show the act of drinking, connect drinking with driving, or claim that alcohol relieves anxiety or increases physical performance |
| Education and training | No guarantees of admission, exam results, qualifications, or training effectiveness; restricted use of institutions, experts, or beneficiaries as endorsers |
| Financial and investment products | The provider must hold the necessary qualifications; ads need appropriate risk warnings and cannot promise principal protection, no risk, guaranteed returns, or future performance |
| Real estate | Property information must be true; no appreciation or return promises, misleading planned-facility claims, or location descriptions based on travel time to a reference point |
| Games and entertainment | Publishing, content, age, probability, monetization, and minor-protection rules may apply in addition to advertising law |
“Educational” health content is not a workaround. The Internet Advertising Measures prohibit disguising advertisements for medical services, medicines, medical devices, health foods, or special medical-purpose formula foods as health or wellness knowledge. Displaying the relevant provider’s address, contact details, or shopping link on the same page can cause the content to be treated as advertising.
Online ads must be recognizable as advertising. Native content, paid search, social posts, and performance marketing cannot be designed to look like independent information when they are commercial promotions.
Important rules include:
These rules apply to the whole user journey, not just the first banner. A compliant headline linked to an unlawful product page, unapproved medical claim, fake countdown, or different seller remains a problem.
KOL posts, product seeding, livestream sales, “store visits,” unboxings, reviews, and experience sharing can constitute advertising even when they do not resemble a conventional banner.
Where promotional content includes a shopping link or other purchase method, it must be clearly marked as an advertisement. Even without a direct link, the general requirement that advertising be identifiable can apply where a brand has paid for or controlled the commercial promotion.
A KOL, livestream operator, MCN, or host may be treated as an advertising operator, publisher, or spokesperson depending on its role. A presenter who uses their own name or image to recommend or verify a product may become a spokesperson and assume corresponding duties.
Spokespersons must base endorsements on facts and must have used the product or received the service. Children under 10 cannot be used as advertising spokespersons. Spokesperson endorsements are also prohibited for several regulated categories, including medical services, medicines, medical devices, and health foods.
Brand contracts should require:
A platform’s “sponsored” tag is helpful, but the brand should still confirm that the disclosure is prominent in the Chinese user interface and that the content itself complies.
Advertisements must not damage minors’ physical or mental health.
Advertising is generally prohibited in primary and secondary schools and kindergartens, as well as in textbooks, teaching materials, exercise books, stationery, teaching aids, uniforms, and school buses, except for public-service advertising.
Media directed at minors must not carry ads for medical services, medicines, medical devices, health foods, special medical-purpose formula foods, cosmetics, alcohol, beauty services, or online games harmful to minors.
Ads for products or services directed at children under 14 must not:
Age targeting also creates data issues. Under the PIPL, all personal information of children under 14 is sensitive personal information. Processing it requires parental or guardian consent, a specific processing policy, sufficient necessity, and enhanced safeguards.
Audience creation, customer matching, retargeting, lookalike audiences, location targeting, conversion pixels, device identifiers, CRM uploads, and attribution tools can involve personal-information processing.
The Personal Information Protection Law requires a lawful basis, transparency, a clear and reasonable purpose, data minimization, appropriate retention, security, and a way for individuals to exercise their rights.
Where automated decision-making is used for information feeds or commercial marketing, the advertiser or relevant data controller must provide either a non-personalized option or a convenient way to refuse. Targeting also must not result in unreasonable differential treatment in transaction terms.
Advertisements sent by email, direct message, or other electronic means require the recipient’s consent or request. The sender must identify itself, provide contact information, and offer a way to reject future marketing. Internet ads also must not be inserted into messages sent by users, and ads should not be pushed to vehicles, navigation devices, or smart appliances without consent or after refusal.
Advertisers should confirm:
Uploading an overseas customer list to a Chinese advertising platform—or exporting China campaign data into a global CRM—may require additional PIPL analysis. A media-platform contract alone does not resolve the brand’s data obligations.
Yes, but AI does not reduce the advertiser’s responsibility for truthfulness, intellectual property, personal rights, or prohibited content.
AI-generated images, video, audio, text, virtual presenters, testimonials, product demonstrations, and crowd scenes should be reviewed for:
The Measures for Labelling AI-Generated and Synthetic Content, effective since 1 September 2025, establish visible and metadata labelling obligations across the creation and distribution chain. Brands publishing AI-generated content through Chinese online services should preserve required labels and use platform disclosure functions rather than stripping metadata during editing or export.
Enforcement is already practical. Beijing authorities have penalized AI-generated advertising that impersonated a well-known presenter, while Chongqing authorities have taken action against AI-created videos that fabricated crowds and vehicle demand. SAMR’s 2026 policy also identifies AI impersonation of experts, scholars, business figures, doctors, and celebrities as an enforcement priority.
The advertisement, landing page, store, checkout, and customer-service process should tell the same story.
Review at least the following:
Claims made after the click can still be advertising or commercial promotion. Customer-service representatives and AI chatbots should not introduce unapproved claims that the creative-review process removed.
A practical campaign process is:
Verify that the product or service may legally be sold and advertised in China. Identify the seller, importer, distributor, licence holder, and customer-service entity.
Select the legal advertiser, platform account holder, agency, payment route, landing-page operator, and data roles. Confirm each platform’s current onboarding requirements.
Collect business, trademark, product, sector, advertising-approval, website, app, and authorization documents. Resolve inconsistent entity names before submission.
List every intended claim, disclosure, source, evidence item, approved wording, prohibited variation, and expiry date. Include visual and implied claims—not only written text.
Review Chinese copy, images, subtitles, audio, KOL scripts, promotions, targeting, landing pages, consent mechanisms, and customer-service answers. Confirm ad labels and mandatory warnings are visible on the actual device.
Secure the applicable advertising review approval before publishing a regulated advertisement. Do not alter approved content without checking whether new approval is required.
Provide the complete qualification and creative package. Treat platform questions as an additional review layer, not as a substitute for the advertiser’s legal check.
Test every device, placement, link, form, coupon, chatbot, and conversion event. Confirm the advertiser, claims, price, labels, close controls, consent flow, and destination are correct.
Capture the published ad, targeting, publication dates, spend, platform approval, URLs, KOL content, revisions, performance records, complaints, and takedowns. Pause any campaign that deviates from the approved version.
For internet campaigns, the advertiser’s archive should be maintained for at least three years after publication ends. Agencies and publishers have parallel recordkeeping duties.
The archive should include:
Screenshots alone may not show dynamic or personalized content. Where possible, preserve screen recordings, page files, timestamps, account logs, and the targeting conditions that produced the ad.
Penalties depend on the violation and the parties involved.
For a false advertisement, an advertiser can be ordered to stop publication and eliminate its effects and can be fined three to five times the advertising cost. If the cost cannot be calculated or is unusually low, the fine can be RMB 200,000 to RMB 1 million. Repeated or serious violations can lead to fines of five to ten times the cost or RMB 1 million to RMB 2 million, possible business-licence revocation, and loss of advertising approval.
Certain prohibited ads can lead to fines of RMB 200,000 to RMB 1 million. Violations involving regulated sectors, required prior review, education, investment, alcohol, real estate, or spokespersons can also generate substantial cost-based or fixed fines.
Internet-specific violations can result in additional penalties. Failure to provide a compliant one-click close control, unlawful messaging, and certain other format violations can lead to orders to correct and fines. Administrative penalty decisions are publicly disclosed through the National Enterprise Credit Information Publicity System, and serious cases may be added to the serious-illegal-and-dishonest list.
Other consequences may include:
China’s enforcement is active. SAMR reported that authorities handled 44,500 advertising-law cases and imposed RMB 252 million in confiscations and fines during 2025.
Common problems include:
The most effective way to avoid these problems is to design the advertiser structure, qualification file, claims matrix, data flow, and approval process before creative production begins.
AppInChina helps foreign companies plan and operate advertising campaigns across China’s digital ecosystem.
Our support can include:
If your company plans to advertise a product or service in China, contact us for a free initial compliance assessment to determine what you need to safely run ads for your business and/or products in China
