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NMPA Seeks Public Comments on the Implementation of Revisions to the STSC for Cosmetics

Jul 16, 2026
China
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On July 15, 2026, the NMPA released the “Announcement of the National Medical Products Administration on Matters Concerning the Implementation of the Revised Contents of the Safety and Technical Standards for Cosmetics (2015 Edition) (Draft for Comment)”, which is now open for public comment. The public comment period runs from July 15 to July 21, 2026.

The draft clarifies the transitional management requirements for the implementation of revisions to the Safety and Technical Standards for Cosmetics (2015 Edition), and setting out differentiated requirements for cosmetics already on the market, those currently under technical review, and those to be declared. CIRS has translated the content of the draft for public comment for your reference.

The full text is as follows:

In light of the recent revisions to the Safety and Technical Standards for Cosmetics (2015 Edition) (hereinafter referred to as the “Standards”), the following matters are announced regarding the implementation of adjustments to the catalogs of prohibited, restricted, and permitted ingredients, adjustments to the microbial and harmful-substance limits, and the supplementation and updating of testing methods:

I. On the Change and Update of Registration and Filing Information for Products Already on the Market

(1) Revisions to the Standards Involving Adjustments to the Catalogs of Prohibited, Restricted, and Permitted Ingredients

For products that were registered or filed before the revision of the Standards and that require adjustments to their formulas, labels, and other aspects in accordance with the post-revision requirements, the cosmetic registrant or notifier may submit an application for change before the revised contents of the Standards take effect.

Where a relevant ingredient is replaced with a matrix ingredient such as a solvent or filler, or the amount of a relevant ingredient used is reduced, the cosmetic registrant or notifier may explain the circumstances of the formula change and carry out a safety assessment, without the need to conduct registration/filing testing; however, where the adjusted ingredient affects the efficacy of the product, the efficacy shall be re-evaluated, and, based on the efficacy-evaluation results, the product name, label artwork, and other relevant contents shall be changed accordingly.

Where the fragrance is changed, the cosmetic registrant or notifier shall carry out a safety assessment of the fragrance to be changed and provide documentation demonstrating that it complies with the relevant national standards of China or the standards of the International Fragrance Association (IFRA).

For formula adjustments other than the above circumstances, the cosmetic registrant or notifier shall re-conduct registration/filing testing and carry out a safety assessment before submitting an application for change.

(2) Revisions to the Standards Involving Adjustments to the Microbial and Harmful-Substance Limits

Where the revision of the Standards involves adjustments to the microbial limits or harmful-substance limits, the cosmetic registrant or notifier shall carry out a self-inspection and assessment of the registered or filed products.

Where the test reports, assessment results, and other materials in the original registration/filing materials are able to satisfy the post-revision requirements of the Standards, the cosmetic registrant or notifier may, on its own, update the standard implemented by the product, and the product registration/filing materials shall be retained on file for inspection.

Where the test reports, assessment results, and other materials in the original registration/filing materials are not able to satisfy the post-revision requirements of the Standards, the cosmetic registrant or notifier may adopt measures such as adjusting the product’s production process and quality-control measures, and re-conduct registration/filing testing; where the requirements are met, an application for change may be submitted.

(3) Revisions to the Standards Involving Adjustments to Testing Methods

Where the revision of the Standards involves the supplementation and updating of testing methods related to product quality and safety, the cosmetic registrant or notifier shall carry out a self-inspection and assessment to confirm whether the registered or filed products meet the post-revision requirements of the Standards. Where the requirements are met, the standard implemented by the product shall be updated on its own before the revised contents of the Standards take effect, and the relevant safety-assessment materials, test reports, and other materials shall be retained on file for inspection.

Where the testing methods for sunscreen, skin-whitening, and anti-hair-loss efficacy are adjusted, products that have already been registered before the revised contents of the Standards take effect are not required to re-conduct efficacy testing in accordance with the adjusted methods.

II. On the Registration and Filing of Products Under Technical Review or to Be Declared

For products for which registration/filing testing has already been conducted before the revised contents of the Standards take effect, their test reports may be used at the time of registration/filing.

For products currently under technical review, the cosmetic registrant is permitted, during the supplementary-materials stage, to adjust the prohibited, restricted, and permitted ingredients involved in the revision of the Standards. Where a relevant ingredient is adjusted to a matrix ingredient or the amount of a relevant ingredient used is reduced, the circumstances of the formula change may be explained and a safety assessment carried out, without the need to conduct registration testing; however, where the adjusted ingredient affects the efficacy of the product, the corresponding efficacy-test materials for the changed formula shall be provided at the time of submitting supplementary materials; where a relevant ingredient is adjusted to a non-matrix ingredient, registration testing and a safety assessment shall be re-conducted, and the relevant materials shall be provided.

CIRS Reminder

Centered on the three categories of revised contents — ingredient catalogs, safety limits, and testing methods — the Standards set differentiated transitional arrangements for products already on the market, products under review, and products to be declared, and make clear provisions on the circumstances exempting formula changes from testing, the documentation requirements for fragrance changes, the continued validity of original test reports, and the transitional rules for efficacy testing of special cosmetics. It is recommended that the relevant cosmetic registrants and notifiers promptly carry out self-inspection and assessment of their existing products, plan ahead for compliance work such as formula adjustments and materials updates, make full use of the policy consultation window, and complete all preparations before the new rules take effect.

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