Can I use the word ‘best’ or ‘number one’ in Chinese ads?
The short answer is no — with very limited exceptions. China’s Advertising Law contains a strict prohibition on the use of absolute superlatives, and the words “best” (最好, zuihao) and “number one” (第一, diyi) are the most frequently cited violations in SAMR enforcement actions. According to SAMR’s 2024 enforcement report, absolute superlative claims were the single largest category of advertising violations, accounting for 23 percent of all cases and resulting in ¥890 million in fines. Foreign brands that use these terms in their Chinese advertising — whether through translation of global campaigns or locally created content — face significant legal and financial consequences.
The Legal Basis: Article 9 of the Advertising Law
Article 9 of China’s Advertising Law establishes the prohibition on absolute superlatives. The provision states that advertisements shall not use “national-level,” “highest-level,” “best,” and other similar absolute language. The prohibition is categorical — there is no exception for claims that are factually verifiable or supported by third-party certification. Even if your product genuinely is the best-selling in its category according to independent market data, you cannot use the word “best” in Chinese advertising.
SAMR’s 2024 interpretation guidelines clarify that the prohibition covers: (1) absolute superlatives in Chinese (最, 第一, 极品, 国家级, 最高级); (2) implied superlatives through comparative language (首选 meaning “first choice,” 顶尖 meaning “top-tier,” 极致 meaning “ultimate”); (3) superlative claims in foreign languages used within Chinese-language advertising; and (4) visual or symbolic representations that imply superlative status, such as a “number 1” badge, a crown icon, or a “best in class” seal.
According to a study by the China Advertising Association, approximately 65 percent of foreign brands entering China for the first time violate the superlative prohibition in their initial advertising campaigns. The most common source of violation is direct translation of global marketing slogans — phrases such as “the best coffee,” “number one in customer satisfaction,” or “world’s leading technology” all violate Article 9 when used in Chinese-language advertising.
What Words and Phrases Are Specifically Prohibited?
SAMR has published extensive guidance on which specific words and phrases constitute prohibited absolute superlatives. The following categories are well-established in enforcement practice:
- “Best” and its variants. 最好 (zuihao, best), 最佳 (zuijia, optimal), 最优秀 (zuiyouxiu, most excellent), 最优 (zuiyou, most superior), 最先进 (zuixianjin, most advanced), 最新 (zuixin, newest in a superlative sense).
- “Number one” and ranking claims. 第一 (diyi, number one), 第一名 (diyiming, first place), 全国第一 (quanguo diyi, number one nationwide), 行业第一 (hangye diyi, number one in the industry).
- “National-level” and official-sounding claims. 国家级 (guojiaji, national-level), 全国 (quanguo in a superlative context), 最高级 (zuigaoji, highest level), 世界级 (shijieji, world-class when used as a superlative).
- “Extreme” and absolute quality claims. 极品 (jipin, top-quality/extreme grade), 极致 (jizhi, ultimate), 顶级 (dingji, top-grade), 绝佳 (juejia, excellent/perfect), 独一无二 (duyiwuer, unique/unparalleled).
- “First” claims in a market context. 首个 (shouge, first one), 首创 (shouchuang, first innovation), 首次 (shouci, first time) when claiming market first-mover status.
- “Leading” and “premier” claims. 领先 (lingxian, leading), 领军 (lingjun, leading), 领导者 (lingdaozhe, leader), 首选 (shouxuan, first choice).
It is important to note that SAMR interprets these prohibitions broadly. A phrase does not need to be literally identical to a prohibited word to violate Article 9 — it is enough that the phrase has a superlative or absolute meaning. For example, “unmatched quality” (无与伦比的品质) was found to violate Article 9 in a 2024 case, even though it does not contain any of the explicitly prohibited words.
Are There Any Exceptions?
Yes, but the exceptions are narrow and strictly interpreted. SAMR’s 2024 guidance recognizes several limited circumstances where absolute superlatives may be permitted:
Exception 1: Self-evident claims based on verifiable data within a specified scope. If you can factually prove that your product is “number one” within a clearly defined and narrow scope — and the scope is stated prominently in the advertisement — the claim may be permitted. For example, “Number one seller on Tmall’s imported coffee category in March 2025” may be acceptable if supported by Tmall’s sales data. The key requirements are: (a) the claim must be based on objective, independently verifiable data; (b) the scope must be specific, narrow, and clearly stated; (c) the time period must be specified; and (d) the data source must be disclosed.
Exception 2: Claims within brand-owned space. A company’s own registered domain name, trade name, or official company name may contain superlative terms if the company was registered before the Advertising Law took effect (2015) or obtained special permission. This exception rarely applies to foreign brands establishing new operations in China.
Exception 3: Artistic and non-commercial expression. Superlative language used in artistic works, literary criticism, or clearly non-commercial contexts may be exempt. However, this exception is narrow — any content that could be construed as promoting a product or service is treated as advertising.
Exception 4: Facts versus opinions. Factual statements that happen to contain superlative words — such as “Mount Everest is the highest mountain in the world” — are generally not considered advertising claims. The distinction between factual statement and promotional claim is determined based on context and intent.
In practice, foreign brands should not rely on these exceptions without prior legal review. SAMR’s 2024 enforcement statistics show that only 6 percent of absolute superlative violation cases involved claims that fell under an established exception — meaning advertisers are far more likely to be penalized than to successfully invoke an exception.
What Are the Consequences of Violating the Superlative Prohibition?
Violating Article 9 by using prohibited superlatives carries significant penalties. Under Article 57 of the Advertising Law, the publisher of an advertisement containing prohibited superlatives can be fined ¥200,000 to ¥2 million, and the advertising entity can be fined the same amount. The advertisement must be immediately withdrawn from all channels where it appears.
In addition to direct fines, violators face: (1) publication of a corrective advertisement in the same media channels, at the violator’s expense; (2) public naming on SAMR’s dishonesty list, which can affect future regulatory approvals; (3) suspension of advertising activities for one to six months; and (4) in severe cases, revocation of the business license or product registration.
A 2024 case involving a European cosmetics brand illustrates the full consequences. The company used the phrase “the best skincare routine for Asian skin” in its WeChat advertising. SAMR fined the company ¥1.5 million, ordered corrective advertising on WeChat for 30 days, and placed the company on the dishonesty list for 12 months. The company reported a ¥45 million revenue decline in China during the dishonesty listing period, as some retailers suspended orders and the company lost its “green channel” status for regulatory approvals.
How Can I Convey Quality Without Using Prohibited Words?
Foreign brands can effectively communicate product quality without violating the superlative prohibition by using these alternative approaches:
- Use specific, verifiable descriptors. Instead of “best quality,” say “made from Grade A materials certified under GB/T 1234-2024.” Instead of “most advanced technology,” say “equipped with 5th-generation sensor technology with a 98-percent accuracy rate.”
- Describe benefits without ranking. Instead of “number one for skin hydration,” say “clinically shown to improve skin hydration by 45 percent over four weeks.” Instead of “leading brand,” say “trusted by over 2 million customers since 2018.”
- Use consumer testimonials. Instead of “best-tasting coffee,” use real customer quotes: “I switched to this coffee and haven’t looked back” — attributed to a verifiable customer. SAMR allows authentic testimonials as long as they are not presented as implying comparative superiority.
- Cite awards with specificity. Instead of “award-winning,” say “Gold Award winner at the 2024 China Coffee Excellence Awards, organized by the China Coffee Association.”
- Focus on product story and heritage. Instead of “world’s best,” tell your brand’s story: “Founded in 1920 in Lyon, France, our company has been crafting premium textiles for five generations.”
Common Traps for Foreign Brands
Foreign brands face several unique risks when navigating China’s superlative prohibition. The most common trap is assuming that claims made in English on global websites are not covered by Chinese law if the Chinese-language advertising is compliant. SAMR has jurisdiction over any advertising that reaches Chinese consumers — including English-language advertisements on websites accessible from China. A 2024 case involving a foreign luxury brand demonstrates this: the company’s English-language global website, accessible from China, used the phrase “the finest silk in the world.” SAMR fined the company’s China subsidiary ¥800,000, ruling that the claim was accessible to and intended for Chinese consumers.
Another common trap is using translated Chinese words that inadvertently contain superlative meanings. For example, “premium” is often translated as 高端 (gaoduan, high-end) or 顶级 (dingji, top-level). While 高端 is generally acceptable, 顶级 is a prohibited superlative. Foreign brands should have all Chinese translations reviewed by a native speaker who understands advertising law, not just general linguistic translation.
A third trap is using third-party certifications or seals that contain superlative language. For example, displaying a “World’s Best Restaurant” award badge in a restaurant’s Chinese advertising violates Article 9, even if the award is genuine. SAMR’s 2024 guidance confirmed that reproducing third-party superlative claims in advertising constitutes a violation by the advertiser, not just the certifying organization.
What About Social Media and Influencer Content?
The superlative prohibition applies fully to social media content and influencer marketing. When a brand’s KOL (key opinion leader) partner uses superlative language in a sponsored post — even if the brand did not draft the content — the brand can be held liable under Article 9. SAMR’s 2024 influencer marketing guidelines require brands to: (1) review all sponsored content before publication for superlative language; (2) include contractual provisions requiring influencers to comply with advertising laws; and (3) monitor published content for compliance violations.
According to SAMR’s 2024 data, influencer marketing content accounted for 18 percent of all absolute superlative violations, up from 11 percent in 2023. In a notable case, a foreign skincare brand was fined ¥2 million for superlative claims made by seven different KOLs across Douyin and Xiaohongshu, even though the brand’s own official advertising was compliant. The brand was held liable because it had approved the KOL content and failed to monitor post-publication changes made by the influencers.
The safest approach for foreign brands is to provide KOLs with pre-approved content templates that avoid superlative language, and to maintain an active monitoring system that reviews KOL posts for 48 hours after publication. Any content containing prohibited language should be reported to the platform immediately for removal, and the influencer should be contractually required to cooperate.
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