Four Types of Absolute Terms in Packaging Advertising—“100% Safe” and “Zero Risk”: A Practical Compliance Path for Printing Factories Drafting Copy on Behalf of Brands

In June 2024, Lao Zhou, the prepress supervisor at a gift box factory in Wuxi, was added to a WeChat group by a client. The client was the emerging tea beverage brand “Shanlanji,” which wanted to include the phrase “100% natural tea leaves, zero pesticide residues” in the copy for its Mid-Autumn Festival gift boxes. Lao Zhou immediately typed: “Both ‘100%’ and ‘zero’ are absolute terms prohibited under the Advertising Law. I suggest changing them.” The client retorted: “Doesn’t the printing factory just print according to the design draft? Are the absolute terms written by you or by me?”

This rhetorical question actually touches upon the most common risk area in the packaging industry over the past 3 years: printer companies drafting or suggesting copy on behalf of brand owners. Once a prohibited term is determined by the market regulation authority to be illegal, who bears the liability—the brand owner, the sales company, or the printer? Based on the Advertising Law, the Administrative Measures for Advertisements in Printed Materials, and 17 typical cases publicized by local market regulation authorities across various regions from 2024-2026, the true scope of printer companies’ liability is broader than most business owners assume.

This article does not focus on the “prohibited-word list” itself (such content is already oversaturated). Instead, it covers 3 topics: the chain of joint liability for evidence in 4 types of extreme-word scenarios, compliant rewriting approaches for 4 types of wording, and 3 types of self-inspection checklists, enabling printing factories to genuinely avoid fines at the printing stage.

I. True Classification of the 4 Types of Restricted Words—Where the Printing Plant Is Most Likely to Come into Contact with Them

Category 1: The customer’s original design already contains absolute claims, and the printing factory reproduces them as submitted—this is the most common scenario and is also frequently misjudged. The customer’s design states “most environmentally friendly” or “zero additives,” and 90% of printing factory owners believe that “because the wording came from the customer and they did not revise the design, they bear no liability.” However, among the penalty cases publicly disclosed by the market supervision authorities in Wenzhou, Zhejiang, and Zhongshan, Guangdong, in 2024, 4 cases determined that the printing enterprises, as “advertising operators and publishers,” should bear administrative fines of 3-12 × RMB 10,000 on the grounds that “printing and producing packaging boxes containing absolute terms constitutes publishing an advertisement.” This regulatory boundary tightened noticeably in 2024 compared with 2019. Market supervision authorities can now obtain the printing factory’s WeChat order records and printing contracts to determine whether it had “suggested revisions,” “revised the design,” or used “specific communication scripts.”

Category 2: Printing plants suggest that customers should “add a few words to make it more eye-catching,” resulting in the use of absolute claims—this is the true high-risk area. In March 2025, the sales representative of a printing plant in Wuxi suggested adding the wording “Renew and Firm” to the front and “Zero Irritation” to the back of a skincare gift box, stating that customers would be more likely to purchase it. As a result, the brand was reported, the printing plant’s sales representative was summoned for a meeting, and a fine of 50,000 yuan was imposed. This type of “evidence of the printing plant’s recommendations” (WeChat records, emails, and revision numbers of modified drafts) is the key evidence for establishing joint and several liability.

Category 3: The printing plant voluntarily “smooths out the copy” and “polishes the sentences” for the client, resulting in improper replacement of restricted terms—for example, changing the client’s original “natural green tea” to “100% natural green tea.” The printing plant’s defense that it “edited the text” but “not for the purpose of publishing an advertisement” was upheld in an administrative lawsuit before a Shanghai court in 2025, provided that the printing plant could provide complete records of the modifications demonstrating that “the replacements were technical modifications rather than marketing-driven.”

Category 4: The customer’s design contains no superlative claims, but the printer adds a promotional flyer, gift card, or QR code scan page—this is the most difficult category to detect. Many gift box manufacturers include a thank-you card or prize-draw scan page inside the box, and the salesperson casually adds statements such as “the country’s best-selling product” or “the industry leader.” For such “non-primary packaging” advertising materials, 6 cases in Guangdong, Fujian, and Shandong in 2024-2025 resulted in printers being fined separately, with amounts ranging from 10,000 to 30,000 RMB.

II. The Three Layers of Legal Liability for the Printing Plant—Not “Fined Once, Compensate Millions,” but Not “Completely Innocent” Either

Many printing plant owners who see clickbait headlines such as “Fines of 50,000 or 100,000” immediately think, “I’m done with this; I’m switching careers.” The reality is not that dramatic—under Article 53 of the Advertising Law and Article 18 of the Administrative Measures for Advertisements on Printed Materials, printing plants bear the responsibilities of “advertising operators and publishers,” which are distinct from the “advertiser” responsibilities of brand owners. There are three specific levels:

Level 1: Administrative Penalties (Most Common) — The printing plant is found by the market regulation authority to have unlawfully printed packaging containing absolute claims. The fine ranges from RMB 10,000 to RMB 200,000, while the average fine among cases publicly disclosed in 2024-2026 is RMB 38,000. This is an administrative liability and cannot be transferred to the brand owner. The brand owner may also be fined, but the amount is typically higher, ranging from RMB 50,000 to RMB 500,000.

Level 2: Civil Compensation (triggered only in consumer litigation)—If a consumer purchases a product because of the “100% zero additives” label and later discovers that the product actually contains additives, and files a civil lawsuit, the printing company, as a “joint advertiser,” bears joint and several liability for compensation. In 2024, there were 4 publicly disclosed judgments nationwide in such cases, with the printing companies held responsible for approximately 20-40% of the damages.

Level 3: Criminal liability (extremely rare but genuinely possible)—If the absolute terms involve false advertising and a substantial amount of money (typically exceeding 500,000 yuan in sales), Article 224 of the Criminal Law on contract fraud or Article 266 on fraud may be triggered. In 2025, the owner of a printing factory in Jiangsu was found guilty as an accomplice for writing copy claiming “therapeutic effects” on behalf of an e-commerce brand and was sentenced to 1 year’s imprisonment, suspended for 2 years. This is a genuine extreme case, but it requires the elements of “knowing the claims were false, participating, and a large amount of money involved.”

III. Compliant Rewording Templates for Four Categories of Restricted Terms—Ready for Printing Companies to Provide to Customers

When a customer asks the printing factory, “Can this wording be added?”, rather than simply saying “No,” it is better to provide an alternative solution directly. The following are 4 types of phrasing explicitly regarded as “not constituting extreme wording” according to the market regulatory authorities’ standards for 2024-2026:

Category 1: Replacing Absolute Claims with Verifiable Claims—「100% natural」→「sourced from natural production regions」; 「zero additives」→「no artificial additives detected」; 「most popular」→「more than 100,000 units sold」; 「champion quality」→「among the top-selling brands in the category in 2024」. The compliance boundary for such replacements is that verifiable factual evidence must be available—if a claim states 「more than 100,000 units sold」 but actual sales were only 8,000 units, it is still unlawful.

Category 2: Substitution of Medical Claims — “Treat” “Cure” “Eradicate” → “Help” “Soothe” “Helps” “Relieve.” Article 17 of the Advertising Law explicitly prohibits non-medical products from being promoted with medical claims. When printers see words such as “treat,” “cure,” “anti-inflammatory,” or “cancer prevention” on cosmetics, food, or health supplement packaging, they must proactively advise customers to delete or replace them.

Category 3: Comparative Disparagement Substitutes — “More environmentally friendly than those on the market” or “Crushing the competition” → Remove comparative statements and replace them with wording such as “Our own factory is certified by XX” or “Its biodegradability meets the XX standard.” Comparative disparagement also constitutes unlawful conduct under Article 11 of the Anti-Unfair Competition Law, and no specific disparaged party is required; any formulation using the pattern “more X than Y” carries a risk of violation.

Category 4: Substitutions for superlative claims — “Industry No. 1,” “Most Popular,” “Only,” and “Top-tier” should be replaced with “Best-selling in the XX category,” “Widely acclaimed,” or “The craftsmanship originates from the XX production region.” The compliance boundary for superlative claims is that they must be objectively verifiable by data; otherwise, they must be treated as prohibited extreme claims.

IV. Three Types of Printer Self-Inspection Checklists — Review Them 30 Minutes Before Printing

The printing plant may not have the legal team review every order, but taking 30 minutes before printing to go through the 3-category self-inspection checklist can eliminate 95% of potential problems:

Checklist 1: Prohibited-term scan (takes 10 minutes) — Focus on the 8 positions on the front and back of the package: product name, subtitle, advertising slogan, list of selling points, efficacy description, comparative claims, award claims, and brand story. The scanning tool can be the "Prohibited-Term Detection" mini program on WeChat or a custom term list (200+ entries in the absolutized-language term list, 300+ entries in the medical-efficacy term list, and 150+ entries in the comparative-language term list).

Checklist 2: Source Verifiability Check (10 minutes)—For any claim involving numbers, origin, awards, or sales volume, the client must be asked to provide one of three types of evidence: a test report, sales data, or official certification documents. If the client cannot provide such evidence, the printing company should recommend in writing that the claim be deleted or replaced with vague wording such as "widely acclaimed" or "selected."

Checklist 3: Preserve Records of Collaboration (takes 10 minutes)—All revision suggestions, communication scripts, and design draft version numbers must be documented via WeCom / email; verbal communication alone is not sufficient. In a publicly disclosed 2024 case, the printing plant was held responsible for an additional 30-50% because it had no records proving that “the original artwork submitted by the client was already like this.”

Five FAQs: The Details Every Boss Should Ask

Question 1: The customer says, “You only need to handle the printing; I’ll take responsibility for the copy.” Can the printing company be exempted from liability?—No. In 2024, the market regulation authorities in Zhejiang and Guangdong explicitly stated that exemption clauses in printing contracts cannot override administrative liability and may only be used for subsequent recourse. Administrative fines of 1-20 ten-thousand yuan must first be paid by the printing company, which can then seek recourse from the customer.

Question 2: Only 50 gift boxes bearing the superlative term were printed. Will the market regulation authorities investigate?—Yes. In a publicized Wenzhou case in 2024, a printing plant was fined 12,000 yuan even though it had printed only 30 gift boxes (with total printing fees of 90 yuan). The print quantity does not affect the determination of unlawful conduct, but it does affect the fine. Cases involving fewer than 50 copies are typically fined 10,000–20,000 yuan, while cases involving more than 1,000 copies are typically fined 80,000–150,000 yuan.

Question 3: Do printers bear the same liability when they design for clients (including prohibited superlatives) versus merely printing (including prohibited superlatives)?—No. Printing companies that provide design services (including prohibited superlatives) act as “advertising designers” and bear greater liability (with fines typically 1.5-3 times those for printing alone). Printers are advised to sign separate contracts for “design” and “printing” to clearly define the scope of each service and the corresponding responsibilities.

Question 4: The customer’s design contains superlative terms, and the printing plant refuses to print it. The customer hires another plant to print it. Is the printing plant liable?—Generally, no. However, if the printing plant expressly states orally that “there is a risk, so we will not print it” but does not retain written evidence, and the customer later reports the printing plant for “knowingly failing to report it,” the printing plant was found liable for an additional 30% in a 2025 case in Jiangsu. Therefore, even a verbal warning should be followed by a statement such as “We recommend that this be confirmed in writing.”

Question 5: Is there an industry self-regulatory channel for reductions in fines involving prohibited terms?—Yes. Printing factories that voluntarily take corrective action (deleting offending wording, halting production of the affected batches, and providing records of revised drafts) may apply for a reduced penalty during the hearing phase. In 6 cases in Wenzhou, Zhejiang Province, and Zhongshan, Guangdong Province in 2024, printing factories received reductions of 30-50% in fines due to their voluntary corrective action. However, the prerequisite is that corrective action must be taken before the market supervision authority opens a case; corrective action taken after a case has been opened does not qualify.

VI. Further Reading

Practical Guide to Four Types of Prohibited Terms in Cosmetics Packaging Advertising—Classification of Extremal Terms and Alternative Wording in the Cosmetics Industry

Three Categories of Cosmetics Packaging Regulations Take Effect — Mandatory Requirements of the Cosmetics Supervision and Administration Regulation + Labeling Measures

What Color Difference ΔE Is Acceptable for Printed Materials?——The Foundation of Physical Quality Compliance for Printing Plants

Practical Application of 4 Packaging Printing Quality Testing Standards—The Starting Point for Regulatory Compliance in Building a Printing Factory’s Testing Capabilities