Tue, 13 Oct 2026 · 5 new briefsKO · EN · Weekly Brief

China cosmetics code: NMPA waives retests for base-ingredient swaps

· Policy

China’s National Medical Products Administration (NMPA, 国家药品监督管理局) issued Announcement No. 99 of 2026, dated 30 September, on applying revisions to its cosmetics safety standards. Reformulations that swap an affected ingredient for a base ingredient, or use less of it, need no new registration test. This article covers registered products, products under review and efficacy tests.

Unlabelled cream jars, a plain tube and a small amber fragrance bottle on a steel laboratory shelf
Unlabelled cream jars and a small fragrance bottle on a laboratory shelf. Image: CMB

NMPA Announcement No. 99 is dated 30 September 2026

The announcement covers three kinds of revision to the Safety and Technical Standards for Cosmetics (化妆品安全技术规范, “the Standards”). These are changes to the lists of prohibited, restricted and permitted ingredients; changes to limits on microbes and harmful substances; and additions and updates to test methods. It applies to cosmetics including toothpaste.

The full text was carried by Xinhua on 9 October 2026, with the NMPA named as the source.

NMPA Announcement No. 99 of 2026: basic information
ItemDetail
Issuing bodyNational Medical Products Administration (国家药品监督管理局)
Title关于《化妆品安全技术规范》修订内容实施有关事宜的公告
Document numberAnnouncement No. 99 of 2026 (2026年第99号)
Date of announcement30 September 2026
Effective date of the revised StandardsNot stated; the notice refers to “before the revised content takes effect”
ScopeRegistrants and filers of cosmetics (including toothpaste); special cosmetics under technical review; products about to be registered or filed
Note: the announcement sets out transition handling and does not list the revised ingredients or limits. Source: NMPA, ‘关于《化妆品安全技术规范》修订内容实施有关事宜的公告(2026年第99号)’, as carried by Xinhua

Switching to a base ingredient or reducing the amount needs no new registration test

Where the revised ingredient lists require a formula change, registrants and filers may apply for the change before the revised Standards take effect. If they switch the affected ingredient to a base ingredient (基质原料), or use less of it, they explain the change and complete a safety assessment. No new registration or filing test is needed.

If the change could affect the product’s efficacy, efficacy must be re-evaluated. The product name and label may then need to change, according to the NMPA.

Fragrance changes need a safety assessment and proof of national or IFRA compliance

A company that changes a fragrance must carry out a safety assessment of the new fragrance. It must also provide evidence that the fragrance meets the relevant Chinese national standards or the standards of the International Fragrance Association (IFRA).

Any other formula change requires new registration or filing tests and a safety assessment before the change application is submitted.

How Announcement No. 99 treats registered and filed products
RevisionSituationWhat the company does
Ingredient listsSwitch to a base ingredient, or reduce the amountExplain the change and complete a safety assessment; no new registration or filing test
Ingredient listsChange the fragranceSafety assessment plus proof of compliance with Chinese national or IFRA standards
Ingredient listsAny other formula changeNew registration or filing tests and a safety assessment, then apply
Microbe and harmful-substance limitsExisting data meet the new limitsUpdate the product’s standard and keep records on file
Microbe and harmful-substance limitsExisting data do not meet the new limitsAdjust production or quality control, retest, then apply
Test methodsResults and conclusions unchangedUpdate the product’s standard and keep records on file
Test methodsResults or conclusions would changeAdjust production or quality control, retest, then apply
Note: CMB summary of Part 1, items (1) to (3). Source: NMPA, ‘关于《化妆品安全技术规范》修订内容实施有关事宜的公告(2026年第99号)’, as carried by Xinhua

Products tested before the revision need no repeat sunscreen, whitening or hair-loss efficacy tests

For revised limits and test methods, registrants and filers must first carry out a self-assessment of their registered and filed products. Where existing reports already meet the new requirements, they may update the product’s standard themselves and keep the records on file.

Where the revision changes the efficacy test methods for sun protection, spot removal and whitening (祛斑美白) or anti-hair-loss claims, products registered for testing before the revised Standards take effect do not need new efficacy tests under the revised methods.

Test reports issued before the revision can still be used for registration

Part 2 covers products under technical review or about to be submitted. Products whose registration or filing tests began before the revised Standards take effect may use those test reports when they are registered or filed.

For special cosmetics under technical review, registrants may adjust affected ingredients at the supplementary-materials stage. A switch to a non-base ingredient requires new registration tests and a safety assessment.

Scope: transition rules, not the revised lists themselves

  • Part 1 covers changes and updates to products that are already registered or filed.
  • Part 2 covers products under technical review and products about to be registered or filed.
  • Most deadlines in the notice are expressed as “before the revised content of the Standards takes effect” (《规范》修订内容实施前).
  • The notice applies to cosmetics including toothpaste.

Not disclosed in the source

  • The date on which the revised Standards take effect
  • Which ingredients, limits and test methods have changed
  • A deadline for completing change applications
  • Whether imported cosmetics follow any separate procedure

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