China Launches Six Month Enforcement Campaign Targeting Advertising Cautionary Statements

On 13 March 2026, the State Administration for Market Regulation (SAMR) launched a six-month nationwide enforcement campaign targeting disclosure and warning language in advertising. If your business advertises in China, this requires immediate attention.

The campaign focuses on six priority areas: misleading “big print to attract, small print to disclaim” tactics; missing or inadequate mandatory warnings in regulated product categories; misuse of superlative claims; reliance on unverifiable citations; insufficient disclosure of limitations in self-substantiated claims; and deficiencies in platform and publisher oversight.

While the campaign applies across all sectors, SAMR has singled out technology products (including phones, computers, and vehicles), as well as the tourism, catering, internet platform, outdoor advertising, design and production, and market research sectors for heightened scrutiny. Regulated products - such as drugs, medical devices, health foods, and special foods for medical purposes - are also designated as high‑priority targets.

The Six Regulatory Priorities

SAMR has identified six specific areas that inspectors will actively target during the campaign:

1. “Big print to attract, small print to disclaim” tactics - Using prominent text or audio to make headline claims while hiding unfavourable conditions or limitations in small, faint, or fleeting disclaimers. This is especially sensitive to technology products and promotional offers. Any limiting condition must be presented as clearly as the benefit it qualifies.
2. Missing or obscured mandatory health warnings - For drugs, medical devices, health foods, and special foods for medical purposes, mandatory warning statements (e.g., This product cannot replace drugs) must be clearly visible-not omitted or buried in small print. This priority also extends to AI-generated content: using an AI-created likeness of a real person without consent, or deploying an AI persona to recommend products without disclosure, may be treated as false advertising.
3. Unsubstantiated superlative claims - Terms such as “No. 1”, “best”, “first”, “leading”, or “original” are under scrutiny. Where such claims are made, the scope (industry, geography, time period) must align with recognized standards. Artificially narrowing the definition to make a claim technically accurate will not satisfy regulators.
4. Unverifiable citations - Any statistics, research data, or third-party reports used to support a claim must have their source clearly identified and be publicly verifiable. Overstating or misrepresenting qualified research findings is likely to be treated as false advertising. Notably, where an advertiser knows or should know that third-party data cannot be publicly verified, such data may be regarded as having no citation source at all.
5. Self-substantiated claims with undisclosed limitations - Where advertisers rely on internal data or in-house testing to support a claim, any temporal, geographic, or methodological limitations must be clearly disclosed. A claim based on a regional pilot or short-term seasonal data cannot be presented as universally or permanently applicable.
6. Platform and publisher responsibilities - Internet platforms must actively prevent “big print/small print” abuses and promptly remove non-compliant advertisements. Outdoor advertising operators must vet materials before publication. Design and production agencies must ensure disclaimers and citations use legible fonts, proportionate sizing, and adequate color contrast. Market research institutions are expected to operate prudently and avoid implicitly endorsing “first“ or “original” claims through unreasonable narrowing of scope.

Practical Implications

Local regulators will conduct active inspections and publicize enforcement outcomes throughout the six-month campaign. Penalties range from formal warnings and orders to rectify through to administrative fines. High-profile cases are expected to be made public as a deterrent.

Your Action Checklist

For businesses advertising in China, we recommend prioritizing the following steps:

Immediate Actions

• Audit existing advertisements for “big print / small print” mismatches - ensure any condition, limitation, or caveat material to a headline claim is presented in a clearly readable font, size, and colour.
• Verify that all mandatory health and safety warnings are present, prominent, and legible in regulated product categories (drugs, medical devices, health foods, special foods for medical purposes).
• Review all superlative claims (“1”, “best”, “leading”, etc.) - confirm the scope is accurate, credible and not artificially narrowed.
• Audit citations - ensure every statistic or research finding has a clearly identified, publicly accessible source and is not overstated or taken out of context.
• Review self-substantiated claims - ensure any claim based on internal data clearly discloses the time period, geography, and any other applicable limitations.
• Brief AI content teams - ensure any AI-generated images or personas used in advertising are clearly labelled, and that appropriate consent has been obtained where a real person's likeness is used.

Sector-Specific Priorities

• Technology advertisers: Ensure any performance claim (such as speed, battery life, camera quality) that applies only under specific conditions (such as laboratory settings, network type, accessories) states those conditions prominently.
• Tourism and catering: Present discount conditions, blackout dates, and minimum spend requirements directly alongside the price or offer-do not relegate them to small print.
• Healthcare-adjacent products: Never imply that a non-therapeutic product prevents or treats illness. All required statutory warnings must be displayed prominently.
• Online and social media campaigns: Internet platforms are expected to enforce these rules directly. Brief digital teams proactively to avoid ad takedowns and ensure compliance across all formats (short-form video, livestream, in-feed advertising).

Governance and Process

• Update internal creative review processes to incorporate the six regulatory priorities as a formal pre-publication checklist for any advertisement intended for the China market.
• Where global or regional master claims were developed outside China, conduct a specific gap analysis against Chinese advertising requirements - focusing on prominence, clarity, avoidance of unsubstantiated absolute terms, and citation verifiability.
• Brief external agencies and media partners in China on the campaign requirements, particularly design studios and outdoor advertising operators who will be subject to heightened scrutiny.

This alert is provided for general information purposes only and does not constitute legal advice. Please contact the authors (edward.chatterton@dlapiper.com; olivia.huang@dlapiper.com) or your usual DLA Piper contact if you would like to discuss how these developments may affect your business.