On December 12, 2025, the State Administration for Market Regulation (SAMR) of China issued a public consultation notice on the Guidelines for the Enforcement of Advertising Citations (Draft for Comments) (hereinafter referred to as the “Guidelines”). The purpose of the Guidelines is to further standardize the enforcement practices of advertising citation content by regulatory authorities and to guide advertising entities in enhancing their compliance capabilities regarding advertising citations. The following is a summary of the key points of the Guidelines for reference.
What is advertising citation content?
Advertising citation content refers to data, statistics, survey results, abstracts, quotations, or other materials cited from third-party sources in advertisements that are related to the promoted product or service (hereinafter collectively referred to as "products"). An “advertising citation” refers to any advertisement that includes such cited content.
What principles should advertising citation content follow?
Advertising citation content must be truthful, accurate, and lawful. It must not include fabricated, falsified, or unverifiable information, and must not deceive or mislead consumers.
Data Cited in Advertisements
When the cited data is obtained through experiments, measurements, or testing (collectively referred to as “experiments”), the institution issuing the experimental conclusions, measurement results, or testing data (including results and conclusions, hereinafter collectively referred to as “data”) must possess the appropriate legal qualifications and professional capabilities. Its measuring instruments, environmental conditions, and facilities must comply with applicable laws, regulations, administrative rules, mandatory national standards, and technical specifications for metrology.
Experimental, Measurement, and Testing Methods
If national or industry standards exist, the methods used must comply with those standards. In the absence of such standards, generally accepted methods within the relevant industry or field should be adopted.
Note: If the cited experimental conclusions, measurement results, or testing data are only reproducible under laboratory or specific conditions, such conditions must be clearly indicated. If the cited testing data, results, or conclusions apply only to specific samples, or if the issued testing report or certificate is limited to the tested samples, this must be explicitly stated.
Statistical Data or Survey Results Cited in Advertisements
These should be obtained using scientific methods, and the scope of the statistics or survey should be broad and reasonable. If sampling is used, the sample must meet the requirements of scientific validity, representativeness, and general applicability, and the margin of error should fall within a reasonable range.
Note: If the cited statistical data or survey results are only applicable to a specific region, industry, or time period, such limitations must be clearly indicated.
Abstracts and Quotations Cited in Advertisements
These should be quoted verbatim. The source documents or materials must be authentic and verifiable, and the cited viewpoints must be consistent with established scientific knowledge.
How Should the Sources of Advertising Citations Be Indicated?
The sources of advertising citations should be clearly identified. This includes information such as the name of the institution or individual responsible for the experiment, measurement, testing, statistics, or survey, or the title and author(s) of the cited literature or materials.
- If citing from academic journals, the name of the journal, issue number, and publication date should be provided.
- If citing from internet sources, the access or retrieval path (e.g., URL) must be indicated. If the cited online content or access path changes, the advertising content must be updated accordingly to reflect such changes.
When indicating the source, applicable scope, or validity period of advertising citation content through text, images, audio, or video, the presentation must meet the following requirements:
- For text: the font type, size, and color must be clearly legible to the general public under normal viewing conditions.
- For audio: the speech rate, tone, and clarity must be consistent with the rest of the advertisement.
How should font size and typeface be properly used in advertising?
In advertising that includes claims regarding product performance, function, usage, specifications, validity period, promotional terms, etc., it is prohibited to use methods that may obscure or make such information difficult for consumers to recognize. These prohibited practices include:
- Reducing font size,
- Changing typeface,
- Using font colors that are similar to the background,
Such practices must not be used to provide supplementary explanations or to impose restrictions or interpretations on product performance, function, usage, specifications, validity period, or promotional terms that are contrary to common sense or consumer expectations.
How should terms like “Best” or “No.1” be regulated in advertising?
When advertising uses terms such as “best” in a sub-sector, sub-field, or sub-region, or claims to be “No.1” in terms of sales volume, sales revenue, or market share, the following requirements must be met:
- If the referenced industry or field is narrower than those defined in national economic industry classification standards or relevant industry standards, or
- If the referenced geographical area is smaller than a provincial-level administrative region,
then such claims may mislead consumers regarding the market position or competitive advantage of the business entity or its products or services. In such cases, these claims do not fall under the exemption provided in Article 6, Item 6 of the Guidelines for the Enforcement of the Prohibition of Absolute Terms in Advertising.
Other compliance considerations for citation advertising
If the cited data, conclusions, test results, statistical information, or survey findings are valid only under specific conditions, such conditions must be clearly indicated.
Where an advertiser directly or indirectly publishes or disseminates news articles, academic literature, or research reports through paid news placements, academic misconduct, or other improper means—and then uses the data or conclusions therein as cited content in advertising—the market regulation authority shall report the case to relevant competent authorities such as those in charge of press and publishing or science and technology.
Advertisers may use self-substantiated data, including those obtained through experiments, measurements, statistical analysis, or surveys, as citation content in advertisements.
Data, materials, or conclusions generated or synthesized using artificial intelligence (AI), deep synthesis technologies, or similar methods in advertisements shall be regarded as self-substantiated content.
Where a natural person, legal person, or other organization is entrusted by another party to conduct experiments, measurements, statistical analysis, or surveys, and is aware or should be aware that the resulting data or conclusions will be used in advertising, such party shall be deemed to have participated in the design or production of the advertisement. This falls under the definition of an advertising operator as stipulated in Article 2, Paragraph 3 of the Advertising Law.
What are the obligations of advertising operators and publishers?
Advertising operators and publishers are legally required to verify supporting documentation for advertisements and review the accuracy of the advertising content.
If the cited content in an advertisement lacks a source, fails to clearly indicate applicable conditions or validity period, or is inconsistent with the underlying experimental conclusions, measurement results, statistical data, survey findings, or literature sources, advertising operators and publishers must not provide design, production, agency, or publishing services for such advertisements in accordance with the law.
CIRS Compliance Reminder
The release of the Guideline marks a shift toward more refined and science-based advertising supervision, with higher standards set for the authenticity of citation content, source attribution, and font specifications. For cosmetic companies, advertising is not only a key tool for brand communication, but also a critical compliance boundary that must not be crossed. When conducting advertising activities, companies must strengthen the review and verification of citation content to ensure that all referenced data is legally sourced, factually accurate, and clearly and properly presented. This is essential to mitigate compliance risks arising from false or misleading claims.
CIRS recommends that enterprises closely monitor regulatory developments, promptly adjust their advertising strategies, and continuously enhance their advertising compliance management capabilities.
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