On October 8, 2026, China's National Medical Products Administration (NMPA) issued the Announcement on Matters Concerning the Implementation of the Revised Contents of the Safety and Technical Standards (STSC) for Cosmetics. Addressing the catalogs of prohibited/restricted and permitted ingredients of cosmetics (including toothpaste), the microbiological and harmful substance limits, and the test methods, the Announcement specifies differentiated compliance requirements by category for registered/filed products, products under technical review, and products to be submitted for registration/filing.
Compared with the draft for comments released in July, the final version further optimizes the wording and adds key contents such as the handling rules for cases where the changed test methods affect the test results and their determination, and the compliance requirements for fragrance under technical review.
Comparison with the Draft for Comments
On July 15, 2026, the NMPA released the Announcement on Matters Concerning the Implementation of the Revised Contents of the Safety and Technical Standards for Cosmetics (2015 Edition) (Draft for Comments), and the comment period closed on July 21, 2026.
Based on the officially released announcement, CIRS Group has compared and summarized the differences between the final version and the previous draft for comments.
| Section/Content | Draft for Comments (July 15, 2026) | Final Version (No. 99 [2026]) | Difference Note |
| Preamble of the Announcement | In view of the recent revisions to the Safety and Technical Standards for Cosmetics (2015 Edition) (hereinafter referred to as the “Standards”), matters concerning the implementation of the adjustment of the catalogs of prohibited/restricted and permitted ingredients, the adjustment of microbiological and harmful substance limits, and the supplementation and updating of test methods are hereby announced as follows | In accordance with the revisions to the Safety and Technical Standards for Cosmetics (hereinafter referred to as the “Standards”), matters concerning the implementation of the adjustment of the catalogs of prohibited/restricted and permitted ingredients of cosmetics (including toothpaste), the adjustment of microbiological and harmful substance limits, and the supplementation and updating of test methods are hereby announced as follows | |
| Section I heading | I. Matters Concerning the Change and Update of Registration/Filing Information of Marketed Products | I. Matters Concerning the Change and Update of Registration/Filing Information of Registered and Filed Products | |
| I (1), Paragraph 1 | For products registered or filed before the revision of the Standards that need to adjust their formulas, labels, etc. according to the revised requirements, cosmetic registrants and filers may submit change applications before the revised contents take effect. | For products registered or filed before the revision of the Standards that need to adjust their formulas, labels, etc. according to the revised requirements, registrants and filers may submit change applications before the revised contents take effect. | |
| I (1), Paragraph 2 | Where the relevant ingredients are replaced with matrix ingredients such as solvents or fillers, or their usage levels are reduced, …… an explanation of the formula change may be provided together with a safety assessment, without the need for registration/filing tests; however, where the adjusted ingredients affect the product efficacy, efficacy evaluation shall be re-conducted, and the product name, label draft, and other related contents shall be changed based on the evaluation results. | Where the relevant ingredients are replaced with matrix ingredients such as solvents or fillers, or their usage levels are reduced, …… an explanation of the ingredient adjustments may be provided together with a safety assessment, without the need for registration/filing tests; where the ingredient adjustments may affect the product efficacy, efficacy evaluation shall be re-conducted, and the product name, label, and other related contents shall be changed based on the evaluation results. | |
| I (2), Paragraph 2 | Where the test reports and assessment results in the original registration/filing dossiers can meet the revised requirements, …… the product standards applied may be updated by the enterprises themselves, and the registration/filing dossiers shall be archived for reference. | Where the test reports and assessment results in the original registration/filing dossiers comply with the revised requirements, …… the product standards applied may be updated by the enterprises themselves before the revised contents take effect, and the registration/filing dossiers shall be archived for reference. | |
| I (2), Paragraph 3 | Where they cannot meet the revised requirements, …… measures such as adjusting the production processes and quality control may be adopted, and registration/filing tests shall be re-conducted; change applications may be submitted once the requirements are met. | Where they do not comply with the revised requirements, …… measures such as adjusting the production processes and quality control may be adopted, and the corresponding registration/filing tests shall be re-conducted; where the revised requirements are met, change applications may be submitted before the revised contents take effect. | |
| I (3), Paragraphs 1–2 | …… a self-inspection shall be conducted to confirm whether the registered/filed products meet the revised requirements. For products meeting the requirements, the product standards applied shall be updated by the enterprises themselves before the revised contents take effect, and the relevant safety assessment documents, test reports, etc. shall be archived for reference. | …… a self-inspection and assessment of the registered/filed products shall be conducted. Where the test methods specified in the original registration/filing dossiers, compared with the revised test methods, do not affect the test results and their determination, registrants and filers may update the product standards applied by themselves before the revised contents take effect, and the registration/filing dossiers shall be archived for reference. | |
| I (3), Newly added paragraph | Where the test methods specified in the original registration/filing dossiers, compared with the revised test methods, affect the test results and their determination, registrants and filers may adopt measures such as adjusting the production processes and quality control, and re-conduct the corresponding registration/filing tests; where the revised requirements are met, change applications may be submitted before the revised contents take effect. | Newly added in the final version | |
| I (3), Final paragraph | Regarding the adjustments to the efficacy test methods for sun protection, whitening and anti-spot, and anti-hair loss products, products registered before the revised contents take effect need not re-conduct efficacy tests using the adjusted methods. | Regarding the adjustments to the efficacy test methods for sun protection, whitening and anti-spot, and anti-hair loss products, products for which registration tests have been conducted before the revised contents take effect need not re-conduct efficacy tests using the adjusted methods. | |
| II, Paragraph 2 | For products under technical review, cosmetic registrants are allowed to adjust the prohibited/restricted and permitted ingredients involved in the revision of the Standards during the supplementary documentation stage. Where the relevant ingredients are adjusted to matrix ingredients or their usage levels are reduced, an explanation of the formula change may be provided together with a safety assessment, without the need for registration tests; however, where the adjusted ingredients affect the product efficacy, the corresponding efficacy test documents for the changed formula shall be provided when supplementing documents; where the relevant ingredients are adjusted to non-matrix ingredients, registration tests and safety assessment shall be re-conducted, and relevant documents shall be provided. | For special cosmetics under technical review, registrants may adjust the prohibited/restricted and permitted ingredients involved in the revision of the Standards during the supplementary documentation stage. Where the relevant ingredients are replaced with matrix ingredients such as solvents or fillers, or their usage levels are reduced, an explanation of the ingredient adjustments may be provided together with a safety assessment, without the need for registration tests; where the ingredient adjustments may affect the product efficacy, the corresponding efficacy evaluation test documents after the adjustment shall be provided when supplementing documents. Where the relevant ingredients are adjusted to non-matrix ingredients, registration tests and safety assessment shall be re-conducted, and relevant documents shall be provided. | |
| II, Newly added sentence | Where the fragrance is adjusted, a safety assessment shall be conducted on the fragrance to be changed, and documents certifying its compliance with the relevant national standards of China or the standards of the International Fragrance Association (IFRA) shall be provided. | Newly added in the final version |
Note: This translation is for reference only. Please refer to the original Chinese text as the authoritative version.
CIRS Reminder
Focusing on three core dimensions — ingredient catalogs, safety limits, and test methods — this Announcement sets up differentiated transitional compliance schemes by category for registered/filed products, products under review, and products to be applied for, and further clarifies key rules such as the fragrance compliance documentation requirements during technical review, the validity of existing test reports, and the transition period for efficacy testing of sun protection, whitening and anti-spot, and anti-hair loss products. Cosmetics registrants and filers are advised to promptly conduct compliance self-inspections of their existing products, plan in advance for formula optimization, document updating, safety assessment, etc., and make comprehensive compliance preparations.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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