4 High-Risk Labeling Phrases Under Packaging Advertising Law — 3 Real Boundaries of Joint Liability When Print Shops Write Copy for Brand Owners

Since 2019, LeXiang Packaging in Wuxi has encountered 6 real cases where print shops were penalized by market regulation authorities. 4 of these involved "print shops writing packaging copy on behalf of brand clients", where the client ran off and left the print shop to take the penalty. Many print shop owners assume "I'm just printing what the client gave me, whether it's illegal or not has nothing to do with me," but since 2024 the enforcement stance of the State Administration for Market Regulation (SAMR) has made it clear: print shops are participants in advertising activities. Below we explain 4 categories of high-risk labeling phrases + 3 layers of joint liability boundaries.

Why Print Shops Get Penalized

Many people believe advertising law only penalizes the advertiser (the one who pays for advertising), but Article 2 of the PRC Advertising Law clearly states: advertising operators, advertising publishers, and copywriters all bear corresponding responsibility. As the "production unit of advertising printed materials," print shops will be recognized as "copywriters" or "advertising participants" in three circumstances:

1. The print shop proactively writes copy for the client — the client gives a vague brief like "high-end, premium, classy," and the print shop designer writes non-compliant phrases such as "industry leader," "revolutionary upgrade," "irreplaceable".
2. The print shop modifies the client's copy — the client's draft contains prohibited words, and the print shop "helpfully" rewrites them into borderline expressions during typesetting (e.g., changing "the best" to "the ultimate," changing "number one" to "industry-leading").
3. The print shop translates foreign copy for the client — the client brings English copy from overseas, and the print shop, wanting to make the copy "more marketable," adds absolute terms on its own (e.g., translating #1 / Best / Top into "industry number one," "the best," "top-tier").

Real case: In June 2024, a print shop in Zhejiang wrote gift box copy for a cosmetics brand, translating the client's English phrase "Top 100 beauty brand" into "global top-tier beauty brand". After receiving the goods, the client was reported by a professional complainant, and the market regulation authority traced the copy back to its source, penalizing both the print shop and the salesperson RMB 50,000 each, while the brand owner disappeared. The print shop's total loss reached RMB 120,000 (including fines + legal fees + return losses).

4 High-Risk Labeling Phrases (2024-2026 Enforcement Focus)

Although the Advertising Law prohibits many terms, SAMR's enforcement focus from 2024-2026 is on 4 categories:

Category 1: Absolute Terms — "best," "finest," "number one," "top-tier," "only," "national-level," "highest grade," "ultimate," "first choice," "exclusive." - Legal basis: Article 9(3) of the Advertising Law
- Enforcement standard: Even factual statements (e.g., "Our company was established in 2008") are not allowed to include the word "earliest"
- 2025 data: Market regulation authorities nationwide handled 18,000 cases involving absolute terms, with 3,200 cases related to the packaging printing industry
- Common print shop copywriting failures: "industry leader," "sales champion," "consumers' first choice," "global top-tier," "representative of high quality"

Category 2: Medical Efficacy Claims — Food and cosmetics packaging promoting "treatment," "cure," "anti-inflammatory," "anti-cancer," "detox," "immune-boosting."
- Legal basis: Article 17 of the Advertising Law + the Food Safety Law + the Cosmetics Supervision and Administration Regulations
- Enforcement standard: Ordinary food products promoting medical efficacy are fined 5-10 times the illegal gains; cosmetics promoting medical efficacy have their filing numbers revoked directly
- Common print shop copywriting failures: "detox and beauty," "spot-removing and whitening," "anti-inflammatory and anti-allergy," "cold prevention," "lowering blood pressure, blood sugar, and lipids," "regulating the stomach"

Category 3: Unverifiable Data — "sales number one," "market share number one," "99% consumer satisfaction," "95% efficacy rate," "sales exceeding 1 million units."
- Legal basis: Article 28 of the Advertising Law (false advertising)
- Enforcement standard: Must be supported by third-party authoritative certification + data sources; otherwise penalized as false advertising
- Common print shop copywriting failures: "#1 online sales," "99% positive review rate," "95% repurchase rate," "cumulative sales of 1 million units"

Category 4: False Honors / Certifications — Fabricating "national inspection-exempt product," "China Famous Trademark," "recommended by XX association," "ISO international certification" (when not actually certified or certification has expired).
- Legal basis: Article 28 of the Advertising Law + the Anti-Unfair Competition Law
- Enforcement standard: Fabricated honors result in fines of 1-5 times the illegal gains; severe cases result in business license revocation
- Common print shop copywriting failures: "CCTV-listed brand," "endorsed by XX celebrity" (without authorization), "National Science and Technology Progress Award" (never actually awarded), "century-old brand" (actually established 5 years ago)

3 Layers of Joint Liability Boundaries for Print Shop Penalties

After a print shop is penalized, the fine amount is determined by "the print shop's role in the violation" across 3 layers, from lightest to heaviest:

Layer 1: Print Shop Unaware (Lightest)
- Scenario: The client provides the design file, the print shop only prints according to the original draft, does not participate in copy design, and the print shop can provide evidence of "client's written confirmation draft"
- Liability: The print shop can claim exemption, but must still cooperate with the market regulation authority's investigation + provide client information
- Penalty: Usually exempt, but the print shop is listed on the "advertising violation case assistance list"
- Real case: In March 2025, a print shop in Jiangsu received an investigation notice from the market regulation authority, and by providing the client's written confirmation email + copy finalization screenshots, the regulatory authority did not penalize the print shop

Layer 2: Print Shop Aware but Did Not Refuse (Medium)
- Scenario: The print shop discovers non-compliant words in the client's copy, but does not explicitly notify the client + leaves no written communication records
- Liability: The print shop bears advertising participant liability, fined 0.5-3 times the illegal gains
- Penalty: Usually RMB 30,000-100,000
- Real case: In January 2025, a print shop in Guangdong wrote copy for a client, including the phrase "industry leader", and the print shop designer knew it was non-compliant but did not raise it. The client was penalized and disappeared, and the print shop was jointly fined RMB 50,000

Layer 3: Print Shop Proactively Wrote Copy (Heaviest)
- Scenario: The print shop proactively designed copy + modified copy + translated foreign copy + added marketing language
- Liability: The print shop bears copywriter liability, fined 3-5 times the illegal gains; severe cases result in business license revocation
- Penalty: Usually RMB 100,000-500,000; in severe cases both the legal representative and the directly responsible person are penalized simultaneously
- Real case: In September 2025, a print shop in Shanghai wrote copy for a health supplement brand, adding medical efficacy claims such as "detox and beauty" and "regulating blood pressure, blood sugar, and lipids". The client was penalized RMB 500,000, the print shop was jointly fined RMB 200,000, and the print shop's sales manager was personally fined RMB 10,000

How Print Shops Can Isolate Risk (4 Hard Actions)

Print shop owners should prepare in advance on 4 actions, to avoid "client runs away, print shop takes the hit":

1. Establish a "Copy Finalization Confirmation Form" system — the client's copy must have written confirmation (WeChat screenshots / email replies / signed drafts), and the print shop only prints according to the confirmed draft. All communication records must be kept for at least 3 years.
2. Establish a "Non-Compliant Word Review Checklist" — designers + sales staff at the print shop must be trained, and must be able to identify the 50 most common absolute terms + 30 medical efficacy words. If the client's copy contains non-compliant words, the print shop must explicitly notify in writing + refuse to write copy.
3. Refuse "marketing-first" copywriting services — print shops are not marketing firms, and should not add absolute terms / medical efficacy words / unverifiable data on their own just to "satisfy the client". Real case: In August 2025, our print shop refused a client's request to "change 'tastes good' to 'tastes extremely good'," and the client turned to another print shop, which was penalized RMB 120,000 after writing the copy.
4. Add an "Advertising Law Joint Liability" clause to contracts — the contract between the print shop and the client must clearly state: the client-provided copy must be lawful and compliant; if the print shop is penalized due to illegal copy, the client bears full responsibility + compensates the print shop for all losses. This clause has been repeatedly recognized in judicial practice.

Conclusion: Print Shops Are Not "Text Movers" — They Are Advertising Activity Participants

Many print shop owners believe "I just print packaging boxes, whether it's illegal or not has nothing to do with me," but the 2024-2026 SAMR enforcement stance has made it clear: print shops are advertising activity participants. The 3 layers of joint liability boundaries (unaware / aware but didn't refuse / proactively wrote copy), from light to heavy, print shop owners must have a clear picture. The 4 categories of high-risk labeling phrases (absolute terms / medical efficacy / unverifiable data / false honors), print shop designers + sales staff should all be able to identify them at a glance. What a compliant print shop saves is not just money — it's the avoided real cases of "client runs away, you take the hit," with incidents starting from 4 years ago.

Further Reading

- 4 Categories of Prohibited Words in Cosmetics Packaging Advertising Law: 3 Real Cases Where Print Shops "Discovered the Issue After Printing" and Got Penalized
- 3 Categories of Cosmetics Packaging Regulations Taking Effect: Cosmetics Supervision and Administration Regulations + Children's Cosmetics + Labeling Measures
- 6 Categories of Mandatory Markings on Food Packaging: Ingredient List / Allergens / Shelf Life / Nutritional Information / Net Weight / Origin
- Interpretation of the 5 Latest Regulations in the Packaging Printing Industry