China · Advertising framework
Online video advertising for diagnostic tests and services in China
General market orientation, not campaign clearance. Research scope and dates
Product and service rules
Regulated device advertising needs prior review and label consistency
Legal requirement — paraphrased
Applies when: The offer is a regulated device, including an IVD or software where classified as such.
For a regulated medical device, use the registered or filed product basis and the applicable advertising review. Personal-use devices have specific instruction and warning requirements. Determine whether a test or medical software is a device and whether the campaign also promotes a medical institution.
Sources: SAMR Order 21 — regulated product advertising review; Advertising Law of the People’s Republic of China
Advertising identification does not permit a prohibited endorsement
Legal requirement — paraphrased
Medical, drug, device and health-food advertisements have specific restrictions on endorsement and recommendation. Do not use an influencer, patient or health professional to validate efficacy where that recommendation is prohibited. A commercial label cannot cure the prohibited substance of the message.
Sources: Advertising Law of the People’s Republic of China; SAMR Order 21 — regulated product advertising review
Exclude efficacy guarantees, cure rates and prohibited comparisons
Legal requirement — paraphrased
Applies when: The message is medical, drug or regulated-device advertising.
Advertising Law Article 16 prohibits efficacy or safety guarantees, cure/effectiveness rates, specified comparisons and endorsement-based recommendations in medical, medicine and device advertising. An accurate study statistic is not automatically suitable promotional copy.
Classify the offer before applying this rule: device software and an ordinary wellness app do not necessarily follow the same route.
Sources: Advertising Law of the People’s Republic of China · Advertising Law Article 16
Apply the 2025 identification guidance to factual listings and health education
Regulator guidance
Applies when: Mainland Chinese medical institutions or their staff publish information about medical services.
The 2025 identification guidelines distinguish specified factual institutional information from advertising. Tabulated information on a third-party platform can fall outside advertising where it meets the guideline conditions and contains no subjective promotion.
Comparative claims, guarantees, promotional case stories and links from health education to the corresponding medical service can cross the boundary into advertising. A clinician’s name and professional affiliation in genuine educational material are not by themselves equivalent to a promotional endorsement.
Sources: SAMR / NHC / NATCM — Medical Advertising Identification Guidelines, 2025 · Medical Advertising Identification Guidelines sections 5–8
Track approval expiry and the approved creative version
Legal requirement — paraphrased
Under Order 21, advertising approval expires with the earliest relevant underlying product or production document; where those documents have no expiry, the advertising approval lasts two years. Changes to approved content require renewed review. Do not treat a shortened or rearranged video as automatically covered by the original approval.
Sources: SAMR Order 21 — regulated product advertising review
Keep the applicable warning visible throughout video
Legal requirement — paraphrased
SAMR Order 21 requires category-specific warnings and the advertising approval number. OTC ads need the OTC symbol and the instruction to purchase/use according to the leaflet or pharmacist guidance; personal-use devices have their own instruction and applicable contraindication notice. Health-food ads must state that the product is not a medicine and cannot replace medicine for disease treatment, and identify suitable and unsuitable users. Required prominent information must remain visible throughout video, with clear type and colour.
Sources: SAMR Order 21 — regulated product advertising review · Articles 5–10; use the exact Chinese wording from the approved creative.
Channel rules
Check the complete consumer-facing message
Regulator guidance
Advertising must be truthful and clear. Review the accuracy of stated functions, benefits, provider details, prices and promises under the Advertising Law. Sector review requirements and prohibited claims continue to apply even when the advertiser identifies the commercial nature of a message.
Do not disguise regulated advertising as health education
Legal requirement — paraphrased
Reviewed health advertisements must remain within the approved content. Internet rules prohibit disguised medical, medicine, device and health-food advertisements presented as health knowledge; related supplier contacts or shopping links alongside that knowledge are specifically restricted. Paid search needs clear advertising identification.
Health information and automated marketing need separate review
Legal requirement — paraphrased
PIPL treats medical and health information as sensitive personal information, with heightened necessity and protection requirements. Assess applicable separate-consent obligations and the limited non-consent bases. Automated commercial marketing must provide the required non-personalised option or convenient refusal route; check cross-border data flows separately.
Sources: Personal Information Protection Law
Do not apply the ordinary-data threshold to health data
Regulator guidance
The CAC identifies medical and health information as sensitive personal information. Its under-100,000-person ordinary-data exemption excludes sensitive data. Subject to stated exemptions, a non-critical-infrastructure operator exporting sensitive information for fewer than 10,000 people must use the standard-contract or certification route; at least 10,000 requires a security assessment. Important data and critical-infrastructure operators have separate assessment triggers. Count people from 1 January and document the specific exemption, if any; an advertising consent checkbox does not establish a transfer mechanism.
Sources: Cross-border data provisions — official explanatory FAQ
Approve the final audiovisual edit
Editorial recommendation
Review speech, captions, demonstrations, overlay visibility and playback speed. Recheck short edits and silent versions against applicable product warning and disclosure requirements.
Exclude restricted health and beauty ads from media directed at minors
Legal requirement — paraphrased
Applies when: The internet medium is directed at minors and the advertisement falls within an Article 12 sector.
Article 12 prohibits medical, medicine, medical-device, health-food, special-medical-purpose food, cosmetic and beauty advertising on internet media directed at minors. The restriction concerns the medium’s audience and context, not only a chosen targeting checkbox.
First classify the advertised offer within the listed sectors; ordinary wellness content is not automatically a regulated product advertisement.
Campaign workflow
Diagnostics & Health Testing: prepare the review
Editorial recommendation
Separate a test kit, laboratory service, screening package and medical interpretation. State the intended population and explain the limits of a positive or negative result. Review both product rules and provider rules when a device is bundled with a clinical service.
Keep a traceable campaign decision
Editorial recommendation
Keep one review record linking the offer, local market status, claim evidence, exact creative, media settings and any regulatory or professional clearance. Record who checked each condition. Reopen the review when the offer, claim, source rule or execution changes.
Pre-publication checklist
- Separate a test kit, laboratory service, screening package and medical interpretation.
- State the intended population and explain the limits of a positive or negative result.
- Review both product rules and provider rules when a device is bundled with a clinical service.
- Record product or provider eligibility before approving claims.
- Archive the final creative and its evidence, permissions and review decisions.
- Assign an owner for source updates, complaints and prompt withdrawal of inaccurate material.
Scope and unresolved questions
- Mainland only. Beijing TCM review, national online-retail display conditions, warning presentation and a cross-border data route are documented. Other provincial filing procedures, actual seller permissions, platform account rules, product-specific Chinese assets and the transfer facts still require review.
- This national baseline does not review every broadcaster rule, platform policy, regional licensing condition, promotion mechanic or data-transfer arrangement. No format-specific warning dimensions or durations should be inferred where none are supplied.
Research scope, introduction and dates
Advertising diagnostic tests and services in online videos in China requires a distinction between the test product, the laboratory service and the interpretation of the result. Use this framework to review those layers and the limits of the advertised outcome.
A video combines sound, images, captions and timing. Review the full edit and each short-form excerpt, allowing for the relevant warning or disclosure presentation and the possibility that a silent version needs a separate format assessment.
General market orientation, not legal, regulatory or medical advice, a complete compliance plan or clearance of an advertisement. Actual requirements depend on the specific offer and campaign.
How to use this national baseline
Editorial overview
This framework combines researched national rules with editorial review steps. Mainland China only; Hong Kong, Macau and Taiwan are outside this pack. A visible channel workflow does not establish that the selected product or service may be advertised there. Read the category restrictions first.
The review date identifies when the cited provisions or regulator excerpts were checked. It does not mean that every local rule, exception, professional standard or platform policy has been reviewed.
Sources
- SAMR Order 21 — regulated product advertising review
Follow-up review of the cited issue on 25 October 2026; scope and remaining conditions are recorded in the modules and review register.
- Advertising Law of the People’s Republic of China
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- Internet Advertising Measures, SAMR Order 72
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- Personal Information Protection Law
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- SAMR / NHC / NATCM — Medical Advertising Identification Guidelines, 2025
Targeted review on 25 October 2026. This date does not certify the currency of other sources or resolve local and campaign-specific requirements.
- Cross-border data provisions — official explanatory FAQ
Follow-up review of the cited issue on 25 October 2026; scope and remaining conditions are recorded in the modules and review register.
- Internet Advertising Measures — official HTML text
Targeted review on 25 October 2026. This date does not certify the currency of other sources or resolve local and campaign-specific requirements.
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