China · Advertising framework
Paid social campaigns for pharmacies and health retail in China
General market orientation, not campaign clearance. Research scope and dates
Product and service rules
Separate prescription sales controls from advertising permission
Regulator guidance
The online-sales rules require prescription and non-prescription products to be displayed separately. Prescription pages need the specified risk notice; prescription-sales home/main pages must not directly display packaging and labels, and before prescription review the retailer must not provide the purchase service or display leaflet information. A lawful retail listing process does not override the separate restrictions on prescription-drug advertising.
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 each placement and targeting setup
Editorial recommendation
Review every crop, caption, carousel and boosted creator asset. Document targeting inputs and remove health-data audiences unless a separate privacy review supports them.
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
Pharmacies & Health Retail: prepare the review
Editorial recommendation
Separate promotion of the pharmacy from advertising of each medicine or other product. Verify online-supply and delivery permissions independently of advertising eligibility. Review price promotions and inducements under both retail and medicine rules.
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 promotion of the pharmacy from advertising of each medicine or other product.
- Verify online-supply and delivery permissions independently of advertising eligibility.
- Review price promotions and inducements under both retail and medicine rules.
- 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
Pharmacy promotion in paid social campaigns in China needs separate decisions about the retailer, the advertised products and any online supply. Use this guide to keep medicine restrictions, seller permissions and promotional price mechanics in the same review.
For paid social, review each placement variant as well as the caption, advertiser identity, audience setup and landing page. Boosted creator content also brings the commercial relationship and its disclosure into the 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
- 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.
- 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.
- Online medicine sales supervision measures
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.
From framework to action
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