China’s revised chip layout rules bring a patent-style revocation route, upfront identification of original features and punitive damages

Context: China has made expanding domestic semiconductor capacity a national priority, describing the integrated circuit industry as strategic and foundational to economic development and national security (June 26, 2014 Ministry of Industry and Information Technology policy outline). Intellectual property activity has grown with the industry: integrated-circuit patent publications increased 5.6% year-on-year in 2024, while announced layout-design registrations rose 11.8% (August 4, 2025 China Electronics News report).  Under the old layout-design rules (April 2, 2001 State Council regulation), applicants did not have to identify the features claimed to be original, although lack of originality could still be raised later as a ground for revocation; only the China National Intellectual Property Administration (CNIPA) could initiate revocation, while third parties were limited to revocation suggestions; and punitive damages were unavailable.