China Continues to Reform Its Cosmetics Regulatory Framework
In June and July 2026, China’s cosmetics regulatory regime underwent another round of significant developments. These measures form part of China’s broader effort to provide greater flexibility for international product launches, expand the circumstances in which product toxicological test reports may be waived, and revise the regulatory approach to new cosmetic ingredients. This article highlights the key changes and their potential implications for cosmetics companies operating in the Chinese market.
Regulatory Support for “China-First” Launches
On July 29, 2026, the National Medical Products Administration (NMPA) issued Announcement No. 70 of 2026 [1], which expressly encourages international cosmetic products to launch first in China or simultaneously in China and other markets.
For qualifying international new cosmetic products, registrants and notifiers may submit a China-first launch commitment statement instead of evidence that the product is already marketed in the registrant’s or notifier’s country or the country or region of manufacture. Sales packaging from the country or region of manufacture also may be submitted as design artwork. This change removes a practical documentation constraint for companies that previously planned a home-market launch before entering China. It may give international brands greater flexibility to include China in an initial global rollout, although all other applicable product registration or notification, labeling, safety, and quality requirements continue to apply.
Announcement No. 70 also introduces other efficiencies, including shared testing and efficacy data for qualifying similar-formula products, simplified documentation for certain cross-border manufacturing site transfers and changes of domestic responsible persons, as well as reduced routine submission requirements for ingredient safety information.
Animal Testing Exemptions
Announcement No. 70 also indicates the categories of cosmetics that may qualify for an exemption from submitting product toxicological test reports. The covered products include perming products, non-oxidative hair dyes, freckle-removing and whitening products whose effect is achieved solely through physical coverage, and general cosmetics formulated with new ingredients, excluding children’s cosmetics.
Notably, the exemption is subject to important conditions. The manufacturer must hold relevant production quality management system certification issued by the competent authority in its country or region, and the product safety assessment must sufficiently confirm product safety. For international brands pursuing “Cruelty-Free” policies, the expanded exemption may make it easier to align China submissions with global testing strategies.
The new cosmetic ingredient rules reinforce this direction. NMPA’s policy interpretation [2] states that companies may use alternative testing methods accepted by internationally recognized authorities and may seek technical consultation with the review authority when proposing new safety assessment strategies or methods supported by sufficient scientific evidence.
New Cosmetic Ingredient Requirements
NMPA’s revised rules for the registration, notification, and dossier management of new cosmetic ingredients took effect on July 15, 2026 [3], together with supporting technical rules issued by the National Institutes for Food and Drug Control [4].
The revisions reduce the higher-risk functional categories to preservatives, sunscreens, colorants, hair dyes, and freckle-removing and whitening ingredients. This aligns the classification with the categories subject to registration under China’s cosmetics regulations, while ingredients with other functions generally remain subject to notification.
The revised approach also places greater emphasis on existing safety information, safe cosmetic or food use history, internationally accepted testing methods, and avoidance of unnecessary repeat testing. For foreign ingredient suppliers, this may create greater opportunities to rely on existing global data, provided that the evidence is appropriately organized and scientifically supports the China safety assessment.
A Separate New Chemical Registration Proposal
Novel cosmetic ingredients may also require review under China’s separate new chemical substance regime governed by the Ministry of Ecology and Environment (MEE).
Under current MEE Order No. 12 [5], cosmetic products are expressly excluded from the scope of new chemical substance registration; however, the exclusion does not apply when such products are repurposed for other industrial uses or to new chemical substances used as cosmetic raw materials or intermediates. MEE’s draft revision [6] does not reproduce these sector-specific exclusions, creating uncertainty as to how cosmetic products and ingredients will be treated under the revised regime. Companies may therefore need to reassess whether their products or ingredients fall within scope. For more details, please refer to our newsletter - Updates on China’s Draft Chemical Registration Rules.
If finalized in its current version, foreign cosmetic ingredient suppliers may need to coordinate more closely with Chinese importers regarding registration ownership, confidentiality, annual tonnage, and supply-chain responsibilities.
Safety and Technical Standards
NMPA also opened a consultation on implementation arrangements for proposed revisions to the Safety and Technical Standards for Cosmetics (2015 edition) [7]. The draft addresses how companies should respond to changes involving prohibited, restricted, and permitted ingredients, microbiological and harmful substance limits, and testing methods.
This consultation matters for both new and existing products. Companies may need to review whether current formulas, labels, safety assessments, testing reports, and product technical requirements remain aligned with the revised standards. Products already on the market, products under review, and products preparing for registration or notification may each face different transition considerations.
Taken together, these updates reflect China’s stated effort to support cosmetics innovation and reduce unnecessary procedural burdens, while maintaining its emphasis on companies’ responsibility for safety assessment, technical documentation, and post-market compliance.
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We will continue to monitor China’s cosmetics regulatory developments. Please sign up for our newsletters here.
Keller and Heckman assists cosmetics and personal care companies with ingredient compliance, product registration and notification, safety assessment, labeling, testing requirements, and China market-entry strategy. For questions about these updates, please contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), Sharon Tian (tian@khlaw.com) or your existing contact at Keller and Heckman LLP.
[1] https://www.nmpa.gov.cn/xxgk/ggtg/hzhpggtg/jmhzhptg/20260729115807198.html
[2] https://www.nmpa.gov.cn/xxgk/zhcjd/zhcjdhzhp/20260626112058185.html
[3] https://www.nmpa.gov.cn/xxgk/fgwj/xzhgfxwj/20260626114523130.html
[4] https://www.nifdc.org.cn/nifdc/bshff/hzhpjssp/hzpsptzgg/202606261410392098272.html
[5] https://www.mee.gov.cn/gzk/gz/202112/t20211211_963807.shtml
[6] https://www.mee.gov.cn/xxgk2018/xxgk/xxgk06/202606/t20260611_1159143.html
[7] https://www.nmpa.gov.cn/xxgk/zhqyj/zhqyjhzhp/20260715161733180.html