China · Advertising framework
Search advertising for prescription medicines in China
General market orientation, not campaign clearance. Research scope and dates
Product and service rules
Prescription advertising is not an ordinary digital option
Legal requirement — paraphrased
Eligible prescription-medicine advertisements are limited to jointly designated medical and pharmaceutical specialist publications. Internet Advertising Measures article 6 prohibits prescription-drug internet advertising, subject to any express legal exception. A professional login is not itself permission to run an Rx web campaign.
Sources: SAMR Order 21 — regulated product advertising review; Internet Advertising Measures, SAMR Order 72
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
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
Control short copy and dynamic assets
Editorial recommendation
Approve keywords, responsive assets, sitelinks and destinations together. Disable combinations that would lose a required qualification. A landing page is not an automatic substitute for information required in the ad itself.
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
Prescription Medicines: prepare the review
Editorial recommendation
Identify the exact authorised medicine and prescription status. Resolve the public-promotion restriction or permitted route before developing creative. Separate medicine promotion from neutral disease information and healthcare-service advertising.
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
- Identify the exact authorised medicine and prescription status.
- Resolve the public-promotion restriction or permitted route before developing creative.
- Separate medicine promotion from neutral disease information and healthcare-service advertising.
- 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
Prescription-medicine advertising in search ads in China starts with a legal eligibility decision. Establish whether the proposed consumer message is permitted, restricted to limited information or confined to a professional route before developing benefit and risk statements.
Search advertisements leave little space for qualifications. Review the visible copy, extensions and dynamic assets together with the destination, and establish whether the format can carry the information the advertisement requires.
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.
- Internet Advertising Measures, SAMR Order 72
Targeted source review; apply the cited provision to the exact offer and check subsequent changes before launch.
- 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.
- 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.
- 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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