China’s NMPA Issues Comprehensive Guidelines to Reform Cosmetics Regulation

China’s newly released cosmetics guidelines create a more innovative, transparent, and globally aligned regulatory environment. Early compliance will give companies a clear competitive edge in the world’s largest beauty market.

China has released one of its most comprehensive policy documents on cosmetics regulation in recent years, marking a new phase in the modernization of the country’s oversight framework for the sector.

On November 17, 2025, the National Medical Products Administration (NMPA) issued the Opinions on Deepening the Reform of Cosmetics Supervision and Promoting High-Quality Development (hereinafter, the “Opinions”), setting out an ambitious agenda that will shape the industry’s regulatory trajectory through 2030 and lay the foundations for an internationally advanced system by 2035.

Taken together, these Opinions signal the government’s intent to reshape the sector into a more innovation-oriented, transparent, and globally aligned industry. For domestic manufacturers, foreign brands, and ingredient suppliers, the document provides early visibility into policy priorities that will influence future market access, compliance obligations, and product development strategies.

In this article, we examine the key reform measures introduced in the Opinions, assess their implications for cosmetics market participants, and explore how companies can prepare for the upcoming phase of regulatory transformation.

Contextual background

The release of the Opinions comes at a time when China’s cosmetics industry continues to expand in scale and sophistication. As the world’s largest cosmetics market, China reportedly hosts over 20,000 enterprises, with the sector’s transaction volume surpassing RMB 1.07 trillion (US$151.22 billion) in 2024, according to data from industry associations.

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Rising consumer expectations, expanding e-commerce channels, and strong demand for functional and science-driven products have placed new pressures on the existing regulatory system, prompting the government to accelerate efforts to enhance efficiency, transparency, and risk control.

Against this backdrop, the new policy outline signals major shifts in how products are evaluated, labeled, and monitored. Key measures include:

• An “immediate review upon submission” mechanism for innovative products with new efficacy claims;
• Exemptions from proof-of-overseas-sales for certain imported products seeking first-launch status in China;
• Broader acceptance of alternative non-animal testing methods, including domestically generated in-vitro data;
• Stronger oversight of e-commerce channels;
• A new model for electronic labeling (e-labels); and
• Reinforced systems for post-market safety monitoring.

Together, these reforms reflect China’s broader push to cultivate a more innovation-driven, digitally enabled, and globally aligned cosmetics industry. For market participants, the coming years will require proactive adjustment as implementing rules and technical standards come into force. Yet the reforms also present clear strategic advantages: companies that prepare early are likely to benefit from faster market entry, improved regulatory predictability, and stronger positioning in an increasingly sophisticated market.

Key changes proposed

The new NMPA’s Opinions introduce 24 specific reform measures grouped into five strategic areas, namely:

• Promoting innovation;
• Streamlining registration and filing;
• Enhancing supply-chain risk control;
• Upgrading supervision with intelligent tools; and
• Aligning China’s framework with global standards.

Faster pathways for innovation and new product launches

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A central element of the reform is the introduction of an “immediate review upon submission” mechanism for cosmetics featuring new or advanced efficacy claims. Rather than entering a multi-stage pre-review process, dossiers for innovative products will be evaluated as soon as they are submitted. Companies may also request pre-submission consultations to clarify classification and technical expectations before filing, reducing uncertainty and rework during the registration process.

This acceleration is particularly valuable for brands developing functional skincare, targeted treatment products, and novel actives that fall outside the scope of existing efficacy catalogues.

First-launch incentives for imported products

The Opinions also eliminate one of the long-standing entry barriers for foreign brands: the requirement to provide evidence of prior overseas sales. Under the new “first-launch in China” model, qualifying imported cosmetics may enter China even if they have not been marketed abroad. This shift significantly improves market accessibility for global companies and independent labels whose products are designed specifically for Chinese consumers or whose launch strategy prioritizes China over Western markets.

As a result, China can now serve as a primary rather than secondary launch destination, an important shift for multinational companies seeking to accelerate their access to the world’s largest beauty market.

Support for novel ingredients and cruelty-free formulas

Perhaps the most consequential reform for global brands is the shift in how new cosmetic ingredients are evaluated during their initial monitoring period. Historically, ingredients entering China’s “new cosmetic ingredient” (NCI) system were subject to a three-year monitoring phase, often requiring animal testing to demonstrate safety. This requirement was a significant deterrent for cruelty-free brands or companies with strict ethical-sourcing commitments.

Acceptance of domestically generated in-vitro data

Under the new regulatory approach, companies may now submit in-vitro or other recognized non-animal testing methods conducted within China to satisfy safety and toxicology requirements associated with new ingredients.

This shift accomplishes three things:

1. Accelerates market entry for products using innovative or plant-derived actives;
2. Reduces compliance costs associated with animal testing exemptions or delays; and
3. Signals regulatory support for cruelty-free development and the modernization of China’s toxicology review framework.

Importantly, this represents a structural shift in China’s openness to ingredients that are both innovative and cruelty-free, strengthening alignment with international cosmetic science practices.

Simplified documentation and more efficient administrative processes

Several procedural improvements will be implemented to help companies manage SKUs more flexibly, reduce cost and delay, and better align product rollouts with market demand. These include the following:

• For cosmetic lines with similar formulas under the same brand, it will now be possible to share technical and safety documentation, reducing duplication and paperwork during registration or notification.
• For “Special Cosmetics” undergoing site changes or reformulation, previous documentation can often be reused (except for certain required test reports), streamlining re-registration.
• Overall review and approval timelines are expected to shorten, and coordination between national and provincial regulatory bodies will be improved to ensure more consistent and efficient processing.

These procedural improvements will help companies manage SKUs more flexibly, reduce cost and delay, and better align product rollouts with market demand.

Digitalization, post-market oversight, and e-labeling

Digital governance is becoming a central pillar of China’s cosmetics regulatory framework. The Opinions reinforce this trend by advancing e-labeling, strengthening online-market oversight, and embedding digital traceability across the full cosmetics lifecycle.

These changes also reflect China’s broader policy direction under the Cosmetic Supervision and Administration Regulation (CSAR), which increasingly relies on standardized data flows, intelligent supervision tools, and real-time risk monitoring.

Accelerated rollout of e-labeling

The new reform signals a clear shift toward mandatory electronic labeling (e-labels) for cosmetics sold in China. The NMPA emphasizes that e-labels must enhance transparency, readability, and accessibility, particularly for older consumers and other demographic groups that benefit from enriched digital product information.

E-labels are positioned not as simple QR codes but as digital extensions of the regulatory label system, enabling consumers to access full, up-to-date product information beyond what physical packaging can realistically include. For regulators, they provide real-time visibility into product data, traceability, and historical versions of label content, all essential for market surveillance and enforcement.

Strengthened oversight of e-commerce and digital sales

In parallel with e-labeling, the NMPA is tightening its supervision of digital sales channels. This includes:

• Enhanced scrutiny of product listings, ingredient claims, and consumer-facing information
• Stronger obligations for e-commerce platforms to verify authenticity and compliance
• Integration of e-label information into online marketplace ecosystems to support traceability and complaint resolution
• Targeted monitoring of high-risk categories, including “special cosmetics,” children’s cosmetics, and trending functional products

These measures respond to the rapid rise of live-commerce, cross-border e-commerce, and social-commerce channels, where mislabeling and exaggerated claims are more difficult to control.

Lifecycle-based digital supervision

Beyond labeling and online oversight, the Opinions strengthen digital supervision across the entire lifecycle of cosmetics:

• Adverse-reaction reporting systems will be enhanced, enabling faster identification of safety issues emerging in consumer use.
• Data standardization will support early-warning mechanisms that integrate ingredient safety updates, market surveillance results, and consumer reports.
• Traceability requirements will expand, ensuring that every batch  (domestic or imported) can be tracked from production to end consumer.
• Quality management expectations will rise, especially as digital tools allow regulators to conduct targeted inspections and evidence-based risk assessments.

Together, these developments reflect a regulatory environment in which data accuracy, digital readiness, and transparent supply-chain management become central to compliance.

Alignment with international standards and global convergence

The Opinions further emphasize that China aims to build a regulatory system that is scientifically rigorous, internationally aligned, and capable of supporting high-quality development.

This global integration reduces uncertainty for multinational players and helps align cross-market product strategies, lowering duplication of compliance costs.

In the context of growing global demand for cruelty-free, safe, well-documented cosmetics, China’s shift could help make it a more predictable market for global brands.

Impact on foreign companies and ingredient suppliers

Faster pathways for innovative, functional, and cruelty-free products

The introduction of “immediate review upon submission” and the expanded acceptance of in-vitro testing significantly lowers regulatory barriers for foreign companies. For brands relying on advanced actives, plant-derived ingredients, or cruelty-free positioning, these changes open a route to substantially faster approvals: a historic shift away from the legacy three-year monitoring phase that previously constrained new-ingredient launches.

This also enables international brands to time their China launch in parallel with, or even ahead of, global rollouts, a major competitive advantage in a market with short trend cycles and high innovation turnover.

Greater clarity and consistency in documentation requirements

The Opinions strengthen pre-submission consultation mechanisms and unify expectations for ingredient safety assessments, efficacy substantiation, and formula documentation. Shared dossiers for similar formulations reduce administrative workload, while clearer national–provincial coordination minimizes procedural discrepancies between jurisdictions.

For foreign companies navigating China’s regulatory environment, this creates a more predictable, science-based filing pathway.

Expanded opportunities for ingredient suppliers

Developers of botanical extracts, bioactive compounds, and specialty raw materials stand to benefit from:

• More structured pathways for new ingredient filings;
• Recognition of alternative testing methods;
• A regulatory push toward higher-quality, innovation-oriented ingredients; and
• Support for R&D aligned with China’s “silver economy” and functional skincare trends.

Ingredient suppliers that invest in safety assessments and in-vitro data will gain faster access to the world’s largest cosmetics market.

National movement toward global regulatory convergence

China’s commitment to international alignment reduces friction for multinational companies and eases cross-border harmonization of product portfolios. This supports:

• Faster adaptation of globally approved formulations;
• Clearer expectations for documentation; and
• More consistent application of safety and quality benchmarks.

As China’s system becomes more aligned with EU, ASEAN, and ICCR norms, foreign companies will benefit from fewer duplicative compliance processes.

Higher expectations for compliance and data integrity

Elevated post-market responsibilities

While pre-market pathways are becoming faster, post-market requirements are becoming more stringent. Companies must demonstrate strong capabilities in:

• Adverse-reaction monitoring and reporting;
• Rapid safety issue escalation;
• Batch traceability and supply-chain visibility; and
• Continuous label consistency with registered dossiers.

Foreign companies must be prepared for more frequent inspections, data reviews, and enforcement actions under the expanded lifecycle management system.

More demanding data and digital traceability requirements

E-labeling, QR-code traceability, standardized data structures, and mandatory data uploads mean companies must operate with:

• Robust internal databases;
• Error-free digital label management;
• Strong version control; and
• Seamless integration with China’s information platforms.

Data inaccuracies, whether in labeling, ingredient descriptions, or traceability systems, will carry higher compliance risks in the digital regulatory era.

Stricter oversight of online sales and marketing

E-commerce platforms will be held accountable for verifying compliance, meaning:

• Foreign brands must ensure consistent Chinese-language descriptions;
• Marketing claims must align with registered efficacy;
• Ingredient disclosures must be accurate across all channels; and
• Cross-border e-commerce listings will face increased scrutiny.

With China’s digital consumption ecosystem evolving rapidly, companies should expect tighter enforcement across livestreaming, social commerce, and platform-based sales.

Conclusion: Turning China’s cosmetics regulatory reform into competitive advantage

China’s new regulatory blueprint marks a defining moment for the country’s cosmetics sector. By shifting toward a more transparent, science-based, and innovation-oriented framework, the Opinions signal the government’s intention to elevate the industry’s quality, strengthen market order, and build a supervision system capable of supporting long-term, high-quality development. For market participants, this transition represents more than a technical adjustment; it reflects the broader modernization of China’s regulatory ecosystem in line with international best practices.

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In the coming years, authorities are expected to release detailed implementing rules, transitional arrangements, and technical guidelines that will clarify operational requirements across safety evaluation, e-labeling, new ingredient filings, and post-market monitoring. Companies should prepare for periodic updates as pilot programs, particularly those involving electronic labeling and digital traceability, scale toward national adoption. For both domestic manufacturers and international brands, early alignment with the reform agenda will unlock a meaningful competitive edge.

Firms that invest now in scientific substantiation, digital compliance systems, and lifecycle-based quality management will be better positioned to benefit from faster approvals, more predictable oversight, and rising consumer trust in regulated, transparent brands. China’s cosmetics market remains the largest and one of the most dynamic in the world. As regulatory expectations rise in parallel with consumer sophistication, companies that approach compliance as a strategic capability (not merely a cost) will be well placed to lead in this new era of innovation-driven, high-standard industry growth.

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