A Chinese trademark and a Madrid international trademark are not the same thing. They are two completely independent systems with significant differences in purpose, scope of protection, costs, and procedures. The detailed differences are as follows:
Application route: Filed directly with the China National Intellectual Property Administration (CNIPA), usually through a qualified local IP agency like PUYIZHICHAN.
Scope of protection: Limited to mainland China (excluding Hong Kong, Macau, and Taiwan)
Procedure: Application → Examination → Publication → Registration & grant
Applicable scenarios: Brands operating only in the Chinese market, listing on domestic e‑commerce platforms, enforcement or asset filing within China
Cost: Relatively low, calculated per trademark, per class
Application route: Filed through the applicant’s home office to the World Intellectual Property Organization (WIPO) under the “one application, multiple countries” system
Scope of protection: Can designate multiple contracting parties at once (including China, the United States, the European Union, Japan, South Korea, etc.)
Procedure: Requires a domestic base application or base registration → file an international application through the domestic IP office → formal examination by WIPO → substantive examination by each designated office
Applicable scenarios: Brands planning to enter multiple countries/regions simultaneously, seeking unified management and simplified procedures
Cost: Includes a basic fee plus designation fees for each country; overall it is usually more economical than filing separately in each country, but if only a few countries are designated, the cost‑effectiveness may not be better than filing separately
Chinese trademark = Protection only in China
Madrid trademark = Protection in multiple countries through a single system, with China being just one of the eligible designated members
1. If I only want protection in China, which option should I choose?
Choose a separately filed Chinese trademark.
It is less expensive, faster (typically 6–12 months), has stable examination standards, and subsequent changes, assignments, and enforcement are more straightforward.
PUYIZHICHAN provides one-stop service for foreign applicants, including document preparation, translation, notarization, and full-process tracking.
2. If I want protection in both China and Europe/US, which option should I choose?
Choose a Madrid trademark and designate China.
It covers multiple countries in one application, and later renewals, name/address changes can be handled centrally through WIPO, reducing administrative costs.
3. If I already have a Madrid trademark that designates China, do I still need to file a separate Chinese trademark?
Generally not. Once a Madrid registration designates China, it has the same legal effect in China as a directly registered Chinese trademark.
However, in practice, many companies still choose to file a separate Chinese trademark for the following reasons:
When listing on domestic e‑commerce platforms (e.g., Tmall, JD.com), having a separately registered Chinese trademark makes the recordal process easier
For enforcement, administrative actions, pledges, or license recordals, a domestic registration certificate is more convenient
If the basic trademark underlying the Madrid registration is invalidated (the “central attack” issue), the international registration may be affected, whereas a separately filed Chinese trademark would not be impacted
PUYIZHICHAN specializes in helping international brands register, maintain, and enforce trademarks in China, providing tailored solutions based on your business scope and market plans.
