China’s National Medical Products Administration (国家药监局, NMPA) has set out how cosmetics and toothpaste makers should update registered and notified products after revisions to the Safety and Technical Standards for Cosmetics (化妆品安全技术规范). The notice, No. 99 of 2026, was published on 8 October. It covers ingredient lists, microbial and harmful-substance limits, and test methods.
The notice covers ingredient lists, contaminant limits and test methods
NMPA said the notice follows revisions to the Safety and Technical Standards for Cosmetics. These adjust the lists of prohibited, restricted and permitted ingredients, change limits for microbes and harmful substances, and add or update test methods.
The rules apply to cosmetics, including toothpaste, that were registered or notified before the revision. They also cover special cosmetics still under technical review and products about to be filed.
| Issuing body | National Medical Products Administration (国家药监局) |
| Document number | NMPA Notice No. 99 of 2026 |
| Dated | 30 September 2026 |
| Published | 8 October 2026 |
| Scope | Registered and notified cosmetics, including toothpaste; special cosmetics under technical review; products to be filed |
Swapping in base ingredients or cutting amounts needs no new filing tests
Where the revised ingredient lists require changes to a formula or label, registrants and notifiers may apply for a change before the revised content takes effect.
If a company replaces an affected ingredient with a base ingredient such as a solvent or filler, or uses less of it, it can explain the change and carry out a safety assessment without new registration or notification testing.
If the change may affect efficacy, the product must be re-evaluated for efficacy. The product name and label must then be changed in line with the results.
Fragrance changes require proof of compliance with IFRA or national standards
Companies that change a fragrance must carry out a safety assessment of the new fragrance. They must also provide evidence that it meets the relevant Chinese national standards or the standards of the International Fragrance Association (IFRA).
Any other formula change requires new registration or notification testing and a safety assessment before the change application is filed.
New microbial and harmful-substance limits require self-checks
Where limits for microbes or harmful substances have changed, registrants and notifiers must review their existing products. If the original test reports and assessments meet the revised limits, they can update the product’s applicable standard themselves and keep the records on file.
If the original results do not meet the new limits, companies may adjust production processes or quality controls and retest. Products that then comply can apply for a change before the revision takes effect.
Sunscreen, whitening and anti-hair-loss efficacy tests need not be repeated
The same approach applies to test methods. If a revised method does not affect test results or how they are judged, companies can update the standard themselves; if it does, they must retest after any process or quality-control changes.
Products whose registration testing was logged before the revision takes effect do not need to repeat efficacy tests under the adjusted methods for sunscreen, spot removal and whitening, or hair-loss prevention.
Products under review can adjust ingredients at the supplementary stage
Test reports for products that began registration or notification testing before the revision takes effect can still be used when filing.
For special cosmetics under technical review, registrants may adjust affected ingredients when submitting supplementary materials. Switching to base ingredients or reducing amounts needs only an explanation and a safety assessment, plus efficacy data if efficacy may be affected.
Switching to a non-base ingredient requires new registration testing and a safety assessment. Fragrance changes under review follow the same IFRA or national-standard evidence rule.
Coming up · We may follow up when NMPA publishes the revised text of the cosmetics safety standards.
