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China NMPA Releases Operational Guide to Support Pilot Enterprises in Submission of Electronic Label Information

Jan 29, 2026
China
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On January 29, 2026, the Information Center of the China National Medical Products Administration (NMPA) released an operational guide to facilitate the implementation of the Notice on Launching the Pilot Program for Electronic Labels of Cosmetics. The guide is intended to assist pilot enterprises in the standardized submission of electronic label information and related documentation, and to clarify the specific submission requirements. The guide, titled Operational Guide for Electronic Label Information Submission via the Cosmetics Registration and Notification Information Service Platform, has been developed accordingly. The electronic label-related functions on the platform will be officially launched on February 1, 2026.

Detailed Information of the Guide

Overview

Pilot enterprises are required to submit the following materials via the Cosmetics Registration and Notification Information Service Platform: the data structure code for the electronic label URL, the display content of the electronic label, and images of the product’s sales packaging bearing the electronic label. 

Scope of Application

This operational guide applies to pilot enterprises and their designated third-party technical service providers for the purpose of submitting relevant information and materials via the Cosmetics Registration and Notification Information Service Platform.

Pilot enterprises and third-party technical institutions shall follow this guide in compliance with applicable laws, regulations, and technical standards.

Operational Guide for Electronic Label Information Submission

Before cosmetic products (including toothpaste, hereinafter the same) using electronic labels are launched on the market, pilot enterprises shall submit relevant electronic label information via the Cosmetics Registration and Notification Information Service Platform. The submission mainly includes the following three aspects:

  • The method of electronic label system development,
  • Entity information of the organization responsible for system development, and
  • Registration and notification documents related to the electronic label.

If any changes occur in the electronic label information, pilot enterprises shall update and submit the revised information before marketing the cosmetics bearing the updated electronic label.

1. Selecting the Method of Electronic Label System Development

Pilot enterprises shall select the “Method of Electronic Label System Development” in either of the following modules on the Cosmetics Registration and Notification Information Service Platform:

  • “Smart Declaration and Review for Cosmetics – Sales Packaging Upload,” or
  • “General Cosmetics (Toothpaste) Notification Management – Product Label Page.”

Depending on the actual circumstances, pilot enterprises may choose one of the following options:

  • “Self-developed by the enterprise,”
  • “Developed by a third-party technical service provider,” or
  • “Organized and developed by the provincial drug regulatory authority.”

2. Submission of Entity Information for Electronic Label System Developers

To improve the efficiency of information submission by pilot enterprises, entity information of the electronic label system developer may be submitted through either of the following two methods:

(1) Submission by the Pilot Enterprise

Pilot enterprises may submit the relevant information in the module “Cosmetics Registration and Notification Information Service Platform-Smart Declaration and Review/General Cosmetics (Toothpaste) Notification Management -Electronic Label Technical Institution Maintenance-Technical Institution Management.”

  • If the electronic label system is self-developed by the enterprise, the enterprise shall fill in the information of its own technical team.
  • If a third-party technical institution is used, the enterprise shall fill in the information of that third party.

(2) Submission by the Third-Party Technical Institution

If the electronic label system is developed by a third-party technical institution, the pilot enterprise may authorize the institution to submit the relevant information on its behalf. The third-party technical institution shall first register on the National Medical Products Administration (NMPA) Government Services Portal. After logging in, it may submit the required information under the module “Cosmetics Registration and Notification Information Service Platform- Enterprise Information Management-Third-Party Technical Institution Management.” 

The entity information of the electronic label system developer to be submitted by either the pilot enterprise or the authorized third-party technical institution shall include the following:

  • Name of the technical institution
  • Unified Social Credit Code
  • Electronic label service website address
  • ICP filing number
  • Public security filing number
  • Registered address
  • Contact person
  • Contact information

Notes on key fields:

  • The electronic label service website address refers to the URL providing electronic label services.
  • The ICP filing number refers to the website or app registration number issued by the Ministry of Industry and Information Technology (MIIT), typically in the format: “Province Abbreviation + ICP Bei + Entity Serial Number + Website Serial Number.”
  • The public security filing number refers to the safety filing number issued by the public security bureau, typically in the format: “Province Abbreviation + Public Network Security Filing + Serial Number.”

After completing the submission of the entity information, the pilot enterprise shall, under the module “Smart Declaration and Review – Sales Packaging Upload” or “General Cosmetics (Toothpaste) Notification Management – Product Label Page,” select the name of the electronic label system developer from the list under either “Submitted by Pilot Enterprise” or “Submitted by Third-Party Technical Institution.” The system will automatically associate and display the corresponding information.

If any changes occur in the entity information of the electronic label system developer, the pilot enterprise or the authorized third-party technical institution shall update the information in a timely manner to ensure accuracy and authenticity.

3. Submission of Electronic Label Registration and Notification Documents

Pilot enterprises shall submit relevant information on the electronic label of pilot products under the module “Smart Declaration and Review – Sales Packaging Upload” or “General Cosmetics (Toothpaste) Notification Management – Product Label Page” on the Cosmetics Registration and Notification Information Service Platform.

(1) Select the Code Issuing Organization

Pilot enterprises may choose the applicable code issuing organization from “GS1,” “MA,” or a custom option.

  • “GS1” refers to the China Article Numbering Center.
  • “MA” refers to the Zhongguancun Industry and Information Technology QR Code Technology Research Institute.

(2) Enter Information Including:

  • URL-based data structure code
  • Product identifier
  • Net content specifications using electronic labels

Based on the actual situation, the enterprise shall also indicate whether the URL-based data structure code includes:

  • Production identifier
  • Batch number
  • Serial number
  • Production date
  • Expiration date

The URL-based data structure code must include the service website address and the product identifier unit. Accessing this URL should lead to the display page of the product’s electronic label.

  • If a pilot product has multiple net content specifications and each uses a different electronic label, information shall be submitted separately for each specification.
  • If multiple specifications use the same electronic label, information for only one category needs to be submitted.

(3) Upload the “Electronic Label Display Content” File

This file should contain the actual display content shown when scanning the QR code on the product’s sales packaging. It must be stamped with the company seal and uploaded in PDF format, with a file size not exceeding 10MB. If the only difference among versions of the same pilot product is net content specification, only one version of the electronic label display content file is required.

(4) Upload the “Sales Packaging Image with Electronic Label” File

This file should show the actual sales packaging of the pilot product bearing the electronic label QR code. It must be stamped with the company seal and uploaded in PDF format, with a file size not exceeding 10MB. Uploading shall comply with the requirements of Article 32 of the Regulations on the Provisions on the Management of Cosmetic Registration and Filing Data.

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Further Information:
China NMPAIC

 

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