What Does Class 35 Actually Cover?

Class 35 in China covers a broad range of business and advertising services. The most relevant subclasses for foreign brands are:

• Advertising: Advertising agency services, online advertising, billboard advertising
• Business management: Business consultancy, market research, business administration
• Retail and wholesale services: Sales services for specific product categories
• Online marketplace services: Providing online platforms for buyers and sellers
• Import-export agency services

Why Tmall, JD.com, and Other Platforms Require Class 35

This is the single most important reason foreign brands need Class 35: China's major e-commerce platforms — including Tmall, JD.com, Pinduoduo, and Douyin Shop — require trademark registration in Class 35 (or your product class) to open a branded flagship store.

Without Class 35 registration, you cannot:

• Open an official branded store on Tmall Global or Tmall Domestic
• Operate a branded JD.com storefront
• Run a branded WeChat Mini Program store
• Participate in major shopping festivals like 11.11 (Singles' Day)

If a squatter registers your brand in Class 35 before you do, they can legally block your e-commerce entry and potentially demand payment for the registration.

Class 35 Filing Strategy

Option 1: Direct Class 35 Filing

File specifically for 'retail services for [your specific products]' and 'advertising services.' This provides clean, defensible coverage.

Option 2: Broader Specification

Add 'business management,' 'import-export agency,' and 'online marketplace services' for comprehensive protection. Slightly higher risk of office actions but broader coverage.

Option 3: Defensive Filing

Even if you don't currently sell on Chinese platforms, file Class 35 to prevent squatters from blocking your future options.

Recent CNIPA Guidance on Class 35

CNIPA has clarified in recent examination guidelines that Class 35 does not cover the act of selling your own branded products in your own store — that falls under the product's class. Class 35 covers providing retail services for others' products. However, this technical distinction does not change the practical requirement by platforms.

Cost-Benefit Analysis

Class 35 filing cost: approximately USD 300-500 (official fees + agent fees).
Potential cost of not filing: Inability to operate on Chinese e-commerce platforms, legal fees to fight squatters, or ransom payments that can reach tens of thousands of dollars.

The math is simple: file Class 35.