China’s cosmetics rules: animal testing, NMPA and labels

What is the difference between special and general cosmetics in China?

Special cosmetics are hair dyes, perms, spot-removing and whitening products, sunscreens, anti-hair-loss products and anything claiming a new efficacy. They must be registered with the NMPA. Everything else is a general cosmetic, which is filed rather than registered: with the NMPA for imports, and with the provincial regulator for products made in China.

The split comes from Articles 4, 16 and 17 of the Cosmetics Supervision and Administration Regulation (State Council Order No. 727), published on 29 June 2020 and in force since 1 January 2021. It replaced a 35-article regulation with 80 articles.

Five categories the old rules treated as special-use, including hair-growth, hair-removal and deodorant products, had a five-year transition that ended on 1 January 2026, Xinhua reported. Products still carrying those old approvals can no longer be made, imported or sold.

Does China still require animal testing for cosmetics?

Not for most imported general cosmetics. Since 1 May 2021 they can be filed without toxicology test reports if the manufacturer holds a quality-management or GMP certificate issued by a government authority in its home country, and the safety assessment fully confirms the product is safe. Products for children, new ingredients still under monitoring and companies under key supervision are excluded.

The rule is in the NMPA’s provisions on registration and filing documents (Announcement 2021 No. 32), in force since 1 May 2021. Certificates from industry associations do not count, according to the law firm JunHe and the regulatory service ChemLinked. The NMPA’s own website blocks automated access, so these details come from those two secondary sources.

Cruelty Free International says China dropped mandatory animal testing for most cosmetics in 2021. That does not make every product sold in China cruelty-free. The waiver is optional and conditional, most special cosmetics are still outside it, and the sources we read do not explicitly rule out animal tests after a product reaches the market.

What changed in July 2026?

NMPA Announcement 2026 No. 70, published on 29 July 2026, extended the same waiver, on the same certificate and safety-assessment conditions, to perms, non-oxidative hair dyes, whitening or spot products that work only by covering the skin, and general cosmetics that use new ingredients. Products for children are still excluded.

Still outside the waiver: sunscreens, oxidative hair dyes, other whitening and spot-removing products, anti-hair-loss products and products claiming a new efficacy, according to Xinhua and China Food & Drug News reports on the announcement.

The notice follows the NMPA’s opinions of November 2025, which committed the regulator to reducing, replacing and refining animal tests and to adopting non-animal methods faster. It also lets a novel imported product that launches first in China submit a commitment letter instead of proof that it is already sold abroad.

Do cross-border e-commerce products need NMPA registration?

No. Cosmetics imported through cross-border e-commerce retail channels are treated as personal-use items, so the first-import licensing, registration and filing rules do not apply. Platforms must warn buyers that such products may meet their home country’s standards rather than China’s and may carry no Chinese label, and resale is banned.

That treatment comes from a November 2018 notice by the Ministry of Commerce and other departments, and from General Administration of Customs Announcement 2018 No. 194, in force since 1 January 2019. Neither the 2025 opinions nor the July 2026 notice changed it.

How can you check a cosmetic’s registration in China?

Search the NMPA’s online database (data search, cosmetics, at nmpa.gov.cn) or the regulator’s 化妆品监管 app, using the registration or filing number printed on the pack. The NMPA’s consumer advice, reposted by the Shanghai regulator in April 2026, is not to buy if the label does not match the record.

Under the 2021 registration rules, special cosmetics carry 国妆特字 for products made in mainland China and 国妆特进字 for imports. General cosmetics carry 国妆网备进字 for imports, and a province abbreviation followed by G妆网备字 for products made in China.

Numbers issued under the pre-2021 rules carried a G or J after the prefix, and that form still appears on products and in recent official reports, so on its own it is not a sign of a fake.

What must a cosmetic label in China show?

A Chinese-language label, and no medical claims. Under the NMPA’s labelling rules, in force since 1 May 2022, a label may not use medical terms, imply a medical effect or promise absolute efficacy. Efficacy claims must be backed by evaluations under rules in force since May 2021, and sunscreens must be registered as special cosmetics.

Sunscreen labels give SPF from 2 to 50+ and PA from PA+ to PA++++, based on measured values, according to Xinhua and ChemLinked. We have not checked the underlying technical standard ourselves.

• A Chinese label is required (labelling measures, Article 6).
• No medical terms, implied medical effects or absolute efficacy claims (labelling measures, Article 19; the regulation, Article 37).
• Efficacy claims are evaluated under the 2021 efficacy-claim norms, with evidence summaries published for new applications from 1 January 2022.
• Cosmetics for children aged 12 and under carry a small golden shield logo (小金盾) at the top left of the main panel, required for registrations and filings from 1 May 2022. The NMPA says the logo is not a safety or quality certification.