China advertising compliance is broader than removing words such as “best” or “No. 1.” Foreign brands must classify each campaign, substantiate claims before publication, identify internet advertising, control endorsers and agencies, and preserve the version actually released across websites, e-commerce stores, short-video accounts and livestreams.
This guide maps the national framework for commercial teams. It covers the Advertising Law, the Internet Advertising Measures, the 2025 Anti-Unfair Competition Law and the livestream e-commerce rules effective from February 2026. Sector-specific products, platform terms and local enforcement still require separate review.
China advertising compliance map
Start with the message, not the channel name. Decide whether the content directly or indirectly promotes a product or service, who commissioned and published it, whether another person recommends or proves the claim, and whether a restricted product requires approval or cannot be advertised through that channel. A post can be advertising even when it is framed as education, experience sharing or a livestream conversation.
- Advertising Law: the core rules on truthful content, prohibited claims, endorsers, restricted sectors and penalties.
- Internet Advertising Measures: online identifiability, pop-ups, links, records, platform roles, livestreams and algorithmic delivery.
- Anti-Unfair Competition Law: false or misleading commercial promotion, fabricated transactions and reviews, and assistance supplied to another operator.
- Livestream E-Commerce Measures: duties for platforms, livestream-room operators, marketers and service agencies from February 2026.
- Sector rules: additional controls for healthcare, finance, education, food, cosmetics, tobacco, alcohol and other regulated products.
Identify every legal role
A campaign file should identify the advertiser, advertising operator, publisher, endorser, platform, livestream-room operator, livestream marketer and marketer service agency where relevant. One company or person may hold more than one role. Contract labels do not control if the real conduct shows a different role.
Responsibility cannot be outsourced by giving an agency a broad compliance warranty. The advertiser should verify qualifications and supporting documents; agencies and publishers need intake, review and archive controls; platforms have their own duties; and endorsers must comply with actual-use and truthful-recommendation requirements.
Internet advertising and disclosure
Internet advertising must be identifiable so consumers can distinguish it from other information. Paid search, advertorials, experience-sharing posts with purchase links, influencer content, short video, embedded promotions and livestream segments require classification before launch. Merely omitting the word “advertisement” does not prevent content from being treated as advertising.
For each asset, record the account owner, commercial arrangement, targeting method, shopping link, disclosure treatment, approval version and publication period. Where algorithmic recommendation is used, retain the applicable delivery rules and advertising records. Platform terms can be stricter than national law and should be treated as an additional operating layer, not as a substitute for legal review.
Claims substantiation and false advertising
A claim should not be published until the evidence file exists. The Advertising Law treats materially false or misleading statements as false advertising, including presentations that deceive through omission or overall impression. The revised Anti-Unfair Competition Law separately reaches false or misleading commercial promotion and fabricated transactions or reviews.
| Claim type | Pre-publication evidence | Control |
|---|---|---|
| Performance or efficacy | Current test protocol, report, product match and limitations | Use the qualified claim supported by the test |
| Sales, ranking or market share | Named source, geography, period, category and method | Set an expiry date and prohibit unsupported extrapolation |
| Customer review or testimonial | Authenticity, permissions, incentives and typicality assessment | Do not fabricate, suppress material context or organise fake reviews |
| Comparison | Like-for-like criteria and current competitor data | Review both truthfulness and commercial-disparagement risk |
| Environmental or social claim | Defined boundary, methodology and traceable evidence | Avoid broad claims that exceed the measured scope |
Absolute and superlative terms
Advertising Law Article 9 prohibits specified absolute language such as national-level, highest and best. English equivalents, hashtags, visual ranking devices and spoken livestream claims can create the same issue. There is no reliable universal “safe words” list: context, the claim's object and the overall presentation matter.
For an award, ranking or comparison, name the source, date, territory, category and evidence. Do not convert a limited result into an unlimited superiority claim. Article 9 violations carry a distinct statutory penalty route, while false advertising under Article 28 and Article 55 uses a different framework tied to advertising fees and seriousness. Do not describe either range as an average outcome.
KOLs, influencers and celebrity endorsements
A KOL, creator, celebrity, employee or expert may become an advertising endorser when a person other than the advertiser uses their name or image to recommend or prove a product or service. Titles such as ambassador, experience officer or recommendation officer do not remove the legal analysis. The endorsement should be based on fact, and an endorser must not recommend a product they have not used or a service they have not received.
Before engagement, verify identity, age, reputation, recent penalties, product eligibility and actual-use evidence. The contract should lock the approved brief, require clear disclosure where needed, prohibit unsupported improvisation, allocate content ownership, require version and recording retention, and give the brand immediate correction and takedown rights. Restricted categories require specialist advice before any endorser is engaged.
Livestream commerce from February 2026
The 2026 Livestream E-Commerce Measures define responsibilities for platforms, livestream-room operators, livestream marketers and their service agencies. They require controls including identity and qualification checks, truthful presentation, price transparency, live-room management, records, consumer assistance and action against unlawful conduct.
Livestream content that constitutes commercial advertising also triggers the Advertising Law. A person with influence who recommends or proves a product in their own name or image will generally require endorser analysis. Edited clips and re-posted recordings used to promote sales can also constitute advertising. Artificially generated people used in livestream commerce require the applicable labelling and accountability controls.
- Approve the product list, qualifications, claims and price basis before the event.
- Lock the presenter brief and escalation rules for unscripted questions.
- Display the responsible business and required price information clearly.
- Monitor the live feed and retain the approved script, recording and deviations.
- Correct or remove unlawful clips and preserve the incident-response record.
Douyin, Xiaohongshu and other platforms
National law applies across platform formats. Douyin livestreams and short videos, Xiaohongshu notes, WeChat posts, mini-programs and e-commerce product pages differ operationally, but their platform names do not create separate advertising statutes. Teams should map each channel's current first-party rules alongside the national legal requirements and use the stricter applicable control.
Common failure points include undisclosed commercial relationships, shopping links inside apparently independent reviews, creator ad-libs, expired ranking evidence, fake engagement, unauthorised distributor content and global creative translated without China-specific review.
A defensible operating model
- Intake: identify the product, audience, channel, territory, legal roles and intended publication period.
- Claims register: map every objective claim to evidence, owner, limitations and expiry.
- Legal classification: determine advertising status, disclosure, endorsement and sector approval requirements.
- Approval: lock the Chinese master, translations, creator brief, visual layout, landing page and links.
- Publication evidence: archive the version actually published, delivery settings, recording and approvals.
- Monitoring: capture creator deviations, unauthorised resellers, complaints and regulator notices.
- Response: stop distribution, preserve evidence, correct the claim and coordinate platform and regulator communications.
Connected compliance guides
For consumer remedies, complaints and platform selling, use the China Consumer Protection Law guide. Healthcare campaigns require the specialist pharmaceutical advertising, medical device advertising and internet hospital advertising guides.
Official sources
- Advertising Law of the People's Republic of China
- Measures for the Administration of Internet Advertising
- Internet Advertising Identifiability Enforcement Guidelines
- Measures for Supervision and Administration of Livestream E-Commerce
- Anti-Unfair Competition Law of the People's Republic of China
General information only, not legal advice. Information and official-source currency checked on 30 August 2026.
