China does not regulate cosmetics through a single document. Foreign companies must work with a layered system consisting of one State Council regulation, departmental rules, NMPA administrative measures, technical specifications, ingredient inventories, testing methods, national standards, and general laws on advertising, e-commerce, consumer protection, and product quality. The practical challenge is therefore not finding one “cosmetics law,” but identifying which instruments apply to the product, ingredient, claim, manufacturing model, sales channel, and stage of the product life cycle.
This 2026 guide gives overseas brand owners, manufacturers, regulatory professionals, importers, and domestic responsible persons a working map of that system. It focuses on the instruments that normally control market entry and ongoing compliance. Because China regularly amends technical requirements and adds testing methods, companies should use this map together with the continuously updated China Cosmetics Regulations Compilation and the original publications of the National Medical Products Administration (NMPA).
1. How the Chinese cosmetics regulatory hierarchy works
The legal hierarchy matters. A consultation draft is not an enforceable rule, an NMPA announcement may implement a higher-level regulation, and a technical method may apply only to a particular test or ingredient. Reading documents without their status and effective date can lead to incorrect product decisions.
| Level | Typical instrument | What it controls |
|---|---|---|
| Administrative regulation | Regulations on Supervision and Administration of Cosmetics, State Council Decree No. 727 | The basic legal framework, responsible entities, classification, registration or filing, safety, claims, production, post-market duties, enforcement, and penalties |
| Departmental rules | SAMR Orders No. 35, No. 46, and No. 71 | Registration and filing, manufacturing and marketing supervision, and toothpaste regulation |
| NMPA normative documents | Label measures, GMP, children’s cosmetics provisions, adverse reaction rules, online sales measures, dossier requirements, and inspection provisions | Operational duties and dossier, quality, labeling, channel, and post-market requirements |
| Technical specifications and standards | Safety and Technical Standards for Cosmetics, safety assessment guidance, efficacy-claim standards, testing methods, and ingredient requirements | Formula restrictions, safety limits, test design, evidence, evaluation, and technical acceptance criteria |
| General laws | Advertising Law, E-commerce Law, Consumer Rights Protection Law, Product Quality Law, and Anti-Unfair Competition Law | Promotion, online trade, consumer rights, quality liability, and misleading commercial conduct |
The Chinese-language official text is controlling. English translations are useful working tools, but they should not be treated as authoritative where wording, scope, or legal interpretation is disputed.
2. The foundation: State Council Decree No. 727
The Regulations on Supervision and Administration of Cosmetics, commonly called the CSAR in English-language industry practice, took effect on January 1, 2021. It is the foundation of the current regime. It changed China from a predominantly pre-market approval model into a risk-based, whole-life-cycle system that places primary responsibility on the cosmetic registrant or filing entity.
The regulation defines cosmetics, separates special cosmetics from general cosmetics, creates registration and filing pathways for products and new ingredients, requires safety assessment, regulates efficacy claims and labels, establishes manufacturing and marketing controls, and sets post-market duties such as adverse reaction monitoring and recall. It also gives regulators broad powers to inspect, sample, test, order corrective action, suspend production or sale, and impose administrative penalties.
For a foreign company, the most important structural point is responsibility. An overseas registrant or filing entity must designate a Chinese enterprise legal person as its domestic responsible person. That entity handles registration or filing in China, assists with adverse reaction monitoring and recall, assumes agreed quality and safety responsibilities for products released in China, and cooperates with regulatory inspections. The appointment is therefore not merely an administrative address service.
3. The three core departmental rules
Provisions for Registration and Filing of Cosmetics — SAMR Order No. 35
Effective May 1, 2021, Order No. 35 governs registration and filing of cosmetic products and new cosmetic ingredients. It specifies the authorities, applicants, domestic responsible persons, submission platform, technical review, changes, renewals, cancellations, and safety monitoring of new ingredients. Special cosmetics require registration before manufacture or import. General cosmetics require filing before domestic marketing or import, but filing does not eliminate subsequent technical review, correction, inspection, or enforcement.
Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics — SAMR Order No. 46
Effective January 1, 2022, Order No. 46 governs production licensing, quality systems, entrusted manufacturing, product release, distribution records, online and offline marketing, sampling, inspection, recall, and legal responsibility. It requires the registrant or filing entity to maintain an effective quality management system and confirms that the entity remains responsible when production is outsourced.
Provisions for Toothpaste Regulation — SAMR Order No. 71
Effective December 1, 2023, Order No. 71 created a dedicated framework for toothpaste. Toothpaste is subject to filing, while new toothpaste ingredients follow the corresponding new cosmetic ingredient system. The rule addresses safety assessment, efficacy evidence, labeling, manufacturing licensing, adverse reaction monitoring, and the duties of overseas filing entities and their domestic responsible persons. Foreign oral-care businesses should not assume that toothpaste can use the same dossier and claim strategy as ordinary cosmetics.
4. Product classification determines the route to market
China divides cosmetics into special cosmetics and general cosmetics. Special cosmetics include products for hair dyeing, perming, freckle removal or whitening, sun protection, anti-hair loss, and products claiming a new efficacy. These products require NMPA registration before manufacture or import. Other cosmetics are generally subject to filing.
The Cosmetic Classification Rules and Catalogue provide the coding logic for efficacy, application area, user group, dosage form, and method of use. Classification affects the application pathway, testing, safety assessment, permitted claims, and label. Products for children, products used around the eyes or lips, spray products, and products involving novel claims or ingredients can trigger additional risk considerations even when they remain general cosmetics.
Classification should be decided before formula lock, testing, packaging, or commercial launch planning. A foreign marketing description does not determine the Chinese legal category. Regulators examine the product’s intended use, formula, mode of action, claim language, target user, and presentation as a whole.
5. Imported cosmetics and the domestic responsible person
Imported special cosmetics are registered with the NMPA, and imported general cosmetics are filed with the NMPA or an authorized provincial authority. The overseas registrant or filing entity must appoint a domestic responsible person in China and create the required account on the cosmetics registration and filing information platform.
A typical imported-product package includes entity and authorization documents, manufacturer information, formula, product executive standard, label sample, test reports, safety assessment materials, and evidence concerning overseas marketing and manufacturing quality management. Products made exclusively for China require a different supporting approach where ordinary overseas marketing evidence is unavailable. Documents issued overseas may also require translation, legalization, authentication, or other formalities depending on their type and the current submission rules.
6. Ingredient controls: existing ingredients, new ingredients, and prohibited or restricted substances
Ingredient compliance is built around several resources rather than one positive list. The Inventory of Existing Cosmetic Ingredients in China, generally known as the IECIC, identifies ingredients with an established use status in China. In 2025, NMPA divided the inventory into List I and List II and introduced dynamic updates. Inclusion does not by itself prove that every use, concentration, route of exposure, product type, or user group is safe and lawful.
The Safety and Technical Standards for Cosmetics contain prohibited ingredients, restricted ingredients, permitted preservatives, sunscreens, colorants, and hair dyes, together with limits, conditions, warnings, and technical methods. NMPA announcements may add or revise ingredients and methods between major editions, so companies must check the current consolidated position rather than relying on an old PDF or a supplier statement.
A natural or synthetic ingredient used in cosmetics for the first time in China is a new cosmetic ingredient. Higher-risk functions, including preservation, sun protection, coloration, hair dyeing, and freckle removal or whitening, are subject to registration; other new ingredients are generally subject to filing. Registered or filed new ingredients enter a three-year safety monitoring period and may be incorporated into the inventory after completing that period without identified safety concerns.
On July 15, 2026, the revised Provisions for Registration and Filing Dossiers of New Cosmetic Ingredients and the supporting General Technical Rules for Registration and Filing Dossiers of New Cosmetic Ingredients took effect. New-ingredient developers should therefore confirm the latest requirements for identity, source, manufacturing process, quality control, function, use conditions, safety evidence, and monitoring rather than using a dossier model prepared under the 2021 rules.
7. Registration and filing dossier requirements
The Provisions for Cosmetic Registration and Filing Dossiers and their technical guidance translate Order No. 35 into submission requirements. The dossier typically connects six evidence blocks: the responsible entities, product classification, formula and ingredient data, product executive standard, testing and efficacy evidence, safety assessment, and label.
Foreign companies should pay particular attention to formula naming and raw-material composition. A commercial raw material may contain a functional ingredient, solvent, carrier, preservative, antioxidant, or other component that must be correctly declared. Ingredient safety information may be linked through supplier reporting codes, but the product registrant or filing entity remains responsible for verifying applicability and consistency.
Special-cosmetic registration involves formal acceptance and technical review. General-cosmetic filing permits faster market access, but authorities may conduct technical checks after submission and require corrections or cancel a filing where the dossier is non-compliant or false. A public filing record is not an NMPA endorsement of product safety or efficacy.
8. Safety assessment and testing
The Technical Guidelines for Cosmetic Safety Assessment, 2021 Edition, establish the main safety-assessment framework. The evaluator considers the product formula, ingredient hazards, exposure, systemic exposure dosage, margin of safety where applicable, local tolerance, impurities and risk substances, microbiological risk, stability, packaging compatibility, use conditions, and target population.
NMPA’s 2024 measures introduced classified management for safety-assessment submissions and additional technical tools. By 2026, companies should not assume that the former simplified report remains a general route. They must determine whether a complete report or an eligible basic safety-assessment conclusion may be submitted under the current classified framework, while retaining the underlying assessment for inspection where required.
Registration and filing tests must use applicable Chinese methods and qualified laboratories where the rules require them. The Safety and Technical Standards, NMPA supplementary test methods, efficacy methods, microbiological methods, toxicological methods, stability guidance, preservative-challenge guidance, and packaging-compatibility guidance may all be relevant. Test strategy should be fixed only after the formula, classification, claims, target users, and China-specific dossier route are confirmed.
A major future standard also requires planning. GB 7916-2026, General Safety Requirements for Cosmetics, was published in August 2026 and is scheduled to take effect on January 1, 2028, replacing GB 7916-1987. It is a future-effective mandatory national standard, not a reason to ignore current requirements. Companies with long product-development or packaging cycles should assess the transition early and track related implementation notices.
9. Efficacy claims and claim substantiation
The Standards for Cosmetic Efficacy Claim Evaluation require claims to be supported by scientific evidence and require a summary of the substantiation basis to be disclosed through the NMPA platform. Depending on the claim, evidence may include human efficacy testing, consumer-use testing, laboratory testing, literature, or a permitted combination. The method must match the claim, product, target population, and conditions of use.
Not every global claim can be translated directly into Chinese. Medical claims, express or implied therapeutic effects, false statements, and misleading content are prohibited. Product names, trademarks, images, before-and-after presentations, influencer scripts, marketplace headings, and customer-service statements can all contribute to the regulatory meaning of a claim.
Freckle-removing or whitening, sunscreen, and anti-hair-loss special cosmetics must follow the applicable efficacy evaluation methods in the Safety and Technical Standards for Cosmetics; they are not governed only by the general methods in the efficacy-claim evaluation standard. Claim planning should therefore be completed before testing starts.
10. Chinese labels, advertising, and electronic labels
The Measures for the Administration of Cosmetics Labels, implemented for new registration and filing applications from May 1, 2022, are the main label rules. The minimum sales unit must carry a Chinese label. Mandatory information generally includes the product name, registrant or filing entity, domestic responsible person for overseas products, manufacturer, product executive standard number, full ingredient list, net content, shelf life, directions where necessary, and safety warnings. The label must remain consistent with the registered or filed sample.
Children’s cosmetics are additionally governed by the Provisions for the Supervision and Administration of Children’s Cosmetics and the required children’s cosmetics mark. Formula design should follow safety first, efficacy necessity, and formula minimization, with special attention to the characteristics of children aged 12 and below.
China began a three-year electronic-label pilot on February 1, 2026, in Beijing, Shanghai, Zhejiang, Shandong, Guangdong, and Chongqing, with qualifying offshore duty-free cosmetics in Hainan also able to participate. The electronic label is part of the Chinese label and is subject to specified system, QR-code, content, readability, consistency, and record requirements. It is a controlled regional pilot, not a nationwide permission for every company to replace physical Chinese labeling.
Promotion is also subject to the Advertising Law, Anti-Unfair Competition Law, E-commerce Law, Consumer Rights Protection Law, and platform rules. Registration or filing does not authorize advertising language. All marketing channels should use a claim-control process tied to the approved or filed product positioning and substantiation package.
11. Manufacturing, quality management, and supply-chain controls
The Good Manufacturing Practice for Cosmetics, effective July 1, 2022, sets requirements for organizations and personnel, quality assurance, facilities and equipment, materials, production, testing, product release, records, storage, distribution, and entrusted manufacturing. The registrant or filing entity must maintain oversight even where a contract manufacturer performs production.
The Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics require traceable purchase checks and sales records, qualified product release, annual self-inspection of GMP implementation, risk control, and cooperation with regulatory inspections. The responsible person for quality and safety is a substantive role with qualification and experience requirements, not a ceremonial title.
For imported products, overseas manufacturing evidence must support the China dossier, but a foreign GMP certificate does not resolve formula, label, claim, testing, or safety-assessment gaps. The domestic responsible person should have contractual access to complaint, deviation, batch, distribution, recall, and adverse-reaction information so that China obligations can be performed promptly.
12. Online sales, inspections, adverse reactions, and recall
The Measures for the Supervision and Administration of Online Operation of Cosmetics, effective September 1, 2023, allocate duties among cosmetic marketers, e-commerce platforms, and regulators. Online product information must match registration or filing and label information. Platforms must conduct identity checks, manage operators, monitor illegal conduct, preserve records, and take action when risks or violations are identified.
The Provisions for Cosmetic Inspections, effective November 1, 2024, provide a framework for regulatory inspections. Authorities may conduct routine, cause-based, extended, and other inspections across registrants, filing entities, domestic responsible persons, manufacturers, marketers, suppliers, and relevant technical activities. Companies should expect regulators to test consistency across the electronic dossier, quality system, batch records, supplier files, testing, labels, websites, and actual products.
The Provisions for the Administration of Adverse Reaction Monitoring of Cosmetics, effective October 1, 2022, require monitoring and reporting based on the principle of reporting suspected adverse reactions. Registrants, filing entities, domestic responsible persons, manufacturers, marketers, and medical institutions have different roles. Serious or clustered events can trigger investigation, risk assessment, corrective action, suspension, or recall.
Post-market compliance therefore requires more than renewing a certificate or maintaining a filing. Companies need complaint intake in Chinese, adverse-event triage, distribution traceability, periodic signal review, change control, recall procedures, supplier monitoring, and rapid communication between the global headquarters and the Chinese responsible entity.
13. Other instruments foreign companies should place on their regulatory register
- The Cosmetic Classification Rules and Catalogue, used to determine coding, claim category, user group, application area, dosage form, and method of use.
- The Provisions for Cosmetic Registration and Filing Dossiers, together with current platform manuals, submission notices, and technical review guidance.
- The Inventory of Existing Cosmetic Ingredients and its dynamic updates, plus new-ingredient registration, filing, and safety-monitoring rules.
- The Safety and Technical Standards for Cosmetics, all incorporated amendments, supplementary testing methods, and applicable mandatory national standards.
- The Standards for Cosmetic Efficacy Claim Evaluation and claim-specific methods.
- The Provisions for the Supervision and Administration of Children’s Cosmetics and children’s labeling requirements.
- The Good Manufacturing Practice for Cosmetics, inspection key points, and enterprise quality-and-safety responsibility requirements.
- The Provisions for Cosmetic Inspections, adverse reaction monitoring rules, recall obligations, and sampling or risk-monitoring notices.
- The Measures for the Administration of Cosmetics Labels and the 2026 electronic-label pilot documents.
- The Measures for Online Operation Supervision, together with advertising, e-commerce, consumer, data, and unfair-competition laws.
- The Provisions for Toothpaste Regulation and supporting filing, ingredient, efficacy, label, and technical requirements.
- Product-specific and ingredient-specific notices, standards, inspection methods, policy questions and answers, and transition announcements issued by NMPA, the National Institutes for Food and Drug Control, SAMR, or other competent bodies.
14. A practical market-entry sequence
- Confirm that the product is legally a cosmetic in China and distinguish general cosmetics, special cosmetics, toothpaste, drugs, disinfectants, and other regulated categories.
- Determine the responsible entity, manufacturing model, import route, domestic responsible person, and registration or filing authority.
- Classify the product under the Chinese classification catalogue before confirming claims and tests.
- Screen every ingredient against the current inventory, prohibitions, restrictions, positive lists, use conditions, and new-ingredient status.
- Map ingredient supplier data and reporting codes to the actual commercial raw materials and formula.
- Design the China test, efficacy, stability, packaging-compatibility, microbiological, and safety-assessment strategy.
- Prepare one consistent product executive standard, formula, test sample, safety assessment, claim evidence, and Chinese label.
- Submit the registration or filing dossier and prepare for questions, correction, technical review, or inspection.
- Release production and import only after the applicable legal conditions are satisfied.
- Maintain post-market surveillance, complaint handling, adverse-reaction reporting, traceability, change control, annual obligations, and recall readiness.
15. How to use the China Cosmetics Regulations Compilation
The China Cosmetics Regulations Compilation is designed as a working index rather than a substitute for legal analysis. At the time of this August 2026 update, the page displayed 569 records, including 216 marked currently effective, 34 marked upcoming, and 48 marked for consultation. Because the database is updated dynamically, these numbers will change.
Start with the categories for regulatory regulations, administrative measures, and provisions to identify the governing framework. Then search the technical categories for efficacy evaluation, ingredient standards, safety-assessment templates, guidance, testing and toxicology methods, toothpaste methods, stability, preservative challenge, and packaging compatibility. Always filter by document status and check the publication date, effective date, amendments, replacement notices, and original source. A consultation draft should be used for regulatory intelligence and future planning, not presented as current law.
Useful official starting points include the NMPA cosmetics portal at https://english.nmpa.gov.cn/cosmetics.html, the Chinese NMPA website at https://www.nmpa.gov.cn/, the State Administration for Market Regulation at https://www.samr.gov.cn/, and the National Institutes for Food and Drug Control at https://www.nifdc.org.cn/. For legal decisions, verify the latest Chinese original on the competent authority’s site.
Frequently Asked Questions
Must every imported cosmetic be registered with NMPA?
No. Imported special cosmetics require registration, while imported general cosmetics require filing before import. The route depends on the product’s Chinese classification, claims, ingredients, users, and use method. Filing is not an approval or an exemption from technical review and post-market enforcement.
Can a foreign brand file products without a Chinese entity?
An overseas registrant or filing entity must designate a Chinese enterprise legal person as its domestic responsible person. That entity handles submissions and supports adverse-reaction monitoring, recall, regulatory inspection, and agreed quality and safety responsibilities for products marketed in China.
Does inclusion in the IECIC prove that an ingredient is compliant?
No. IECIC status is only one part of the assessment. The company must also check prohibited and restricted lists, positive lists, concentration and use conditions, product type, exposure route, target population, impurities, safety data, and all later NMPA amendments or risk-control notices.
Can an electronic label replace the physical Chinese label nationwide?
No. The program beginning February 1, 2026 is a controlled three-year pilot in six provincial-level regions, with qualifying offshore duty-free cosmetics in Hainan also eligible. Participation, systems, QR codes, content, readability, consistency, and record controls must meet the pilot requirements.
Which language version should a foreign regulatory team rely on?
Use English translations for orientation, but use the latest official Chinese text for classification, dossier preparation, testing, labeling, legal interpretation, and implementation dates. Maintain a controlled regulatory register that records the source, status, effective date, amendment history, and responsible internal owner.