China Cracks Down on Deceptive Ad Citation ‘Text Traps’

China’s State Administration for Market Regulation (SAMR) has issued new guidelines targeting deceptive “text traps” in advertising citations, marking the first time the regulator has drawn explicit red lines around how companies use data, statistics, and survey results in their marketing. The “Guidelines for Law Enforcement on Advertising Citation Content,” which took effect following a public consultation period that began in December 2025, aim to curb practices that manipulate consumers through misleading language and hidden disclaimers.

The new rules address a range of deceptive tactics that have become widespread in China’s rapidly growing advertising industry, from “big text to attract attention, small text to disclaim” (大字吸睛、小字免责) to artificially narrowed “first place” claims that create misleading impressions of market dominance.

A Growing Industry Under Scrutiny

The regulatory push comes as China’s advertising sector experiences explosive growth. According to Xinhua News, industry revenue exceeded 2 trillion yuan (2.05021 trillion yuan) for the first time in 2025, a year-on-year increase of 32.6% that doubled the industry’s size within five years. Internet advertising has become the dominant channel, generating 612.1 billion yuan in the first half of 2026—up 25.3% year-on-year and accounting for 86% of total advertising revenue.

Enforcement has been aggressive. In the first five months of 2026, market regulation authorities investigated and handled 15,000 advertising violation cases, with fines and confiscations totaling 69.2989 million yuan, according to Gu Baozhong, market inspection specialist at SAMR’s Advertising Regulation Department.

The ‘Text Trap’ Problem

Consumers have borne the brunt of deceptive advertising practices. Li Zixuan, a post-95 consumer in Beijing who regularly shops via livestream commerce, told reporters she frequently hears hosts rattle off long strings of qualifiers at breakneck speed. “The speed was so fast I couldn’t hear clearly. By the time I reacted, the host had already started shouting ‘add to cart,’” she said. Li later discovered that a “first place” claim she had trusted was hedged with a long list of limiting conditions—applying only to a very short time period and a very small group of people.

Shanghai consumer Jia Xiyuan encountered the classic “big text/small text” maneuver on an e-commerce platform. An advertisement for a well-known power strip brand prominently proclaimed “7 out of 10 Chinese households use XX,” but in tiny, nearly illegible text below, the ad revealed the statistic covered all product categories—sockets, switches, lighting, and accessories—not just power strips. “This kind of ‘big text/small text contrast’ that’s common both online and offline made me feel deceived,” Jia said.

Chen Bing, a partner at King & Wood Mallesons, explained that the “big text/small text” advertising model has become a marketing trick for some companies. “Almost every product from some companies has lengthy text requiring a magnifying glass to read behind eye-catching promotional slogans,” he said. Chen noted that advertising marketing has become deeply trapped in “citation dependence,” particularly in new consumer sectors such as cosmetics, tech products, and functional foods, which are “full of various test conclusions, scientific research findings, and statistical rankings, attempting to leverage consumer trust through ‘scientific endorsement.’”

What the New Guidelines Require

The guidelines, published in full by Jiemian News, establish several key requirements:

Burden of proof on advertisers: Advertisers are legally responsible for the truthfulness, accuracy, and legality of all advertising content, including citations, and bear the burden of proof. Zhou Qingjie, dean of the New Business Economics Research Institute at Beijing Technology and Business University, noted that “in the past, some merchants were accustomed to shifting responsibility to third parties—‘the data was given by the institution, it’s not my business.’ This path will no longer work.”

Limits on “first place” claims: “First place” claims cannot be limited to a region smaller than a provincial-level administrative area, or to an industry or field narrower than the national standard industry classification. Products without national standards cannot claim “first place” status at all.

Equal prominence for disclaimers: Supplementary disclaimers that limit main claims must be displayed with equal prominence as the main claim—no font size, color, or visibility differences allowed. As China News Service reported, Wu Shenkuo, a professor at Beijing Normal University Law School, explained that “any supplementary explanation that restricts the main promotional claim must be displayed with equal prominence as the main claim, without differences in font or size.”

Livestream commerce rules: In livestream commerce, restrictive conditions must be explained for a duration not significantly shorter than the main information, with consistent speed, tone, and clarity.

Third-party data scrutiny: Third-party research institutions providing data for advertising may be classified as advertising operators if they knew or should have known the data would be used in ads. This targets the “paid certification” industry that has grown around market research certificates.

AI-generated content: Content generated using AI or deep synthesis technologies is classified as “self-certification content” rather than citation content, with different compliance requirements.

A Shift Toward Multi-Dimensional Governance

Wu Shenkuo characterized the guidelines as marking a fundamental shift in China’s advertising regulatory approach. “Advertising regulation is shifting from single-dimensional review of content truthfulness to multi-dimensional governance of ‘content truthfulness + formal fairness + substantive justice,’” he said. It’s no longer sufficient for information to simply exist in an ad—it must be effectively receivable and understandable by consumers.

Zhou Qingjie views the guidelines as an important measure to address “involution-style” competition in the advertising sector, where companies compete on copywriting rather than product quality. “Everyone is trying to make words sound more beautiful and package data to be more intimidating, but not necessarily making products better,” he observed. The guidelines cut off this path dependence by limiting “data padding” and providing compliance certainty through clear behavioral boundaries.

Legal analysis from Dehe Hantong Law Firm highlights additional implications: distributors and franchisees cannot avoid liability by claiming ad content came from brand headquarters, and the guidelines address the common practice of “paid certification” where companies buy favorable rankings from research institutions.

What’s Next

As the guidelines take effect, market regulation authorities are expected to intensify enforcement across provinces. The SAMR has signaled it will continue its campaign against deceptive advertising, with Gu Baozhong noting that “the regulatory model is accelerating its transformation toward smart, preventive, full-chain proactive governance.”

For businesses, the message is clear: advertising must return to truth and substance. As Zhou Qingjie put it, “When advertising returns to truth and returns to the product itself, its empowerment of the real economy will shift toward quality improvement—not simply helping companies sell things, but helping good companies sell good things.”

Industry observers will be watching how the guidelines are enforced across different regions and how the classification of AI-generated content evolves as AI advertising becomes more prevalent. For consumers, the new rules promise a marketplace where claims can be trusted—and where the fine print is finally legible.