China Cosmetics Regulatory Updates for October 2026: New Ingredient Guidance and Compliance Actions

New Ingredient Filings, Guidance and Consultation Mechanisms

The October roundup records 12 completed new cosmetic ingredient filings, numbered 20260152 through 20260163. These are completed filings, distinct from new ingredient registrations.

On October 30, the NMPA published registration information for BASF SE's new cosmetic ingredient methoxypropylamino cyclohexenylidene ethoxyethyl cyanoacetate (registration certificate No. 20260001), with sunscreen use listed as its purpose. It is the first new sunscreen ingredient registered since the CSAR took effect. Read the REACH24H report on the MCE registration.

On October 8, the National Institutes for Drug Control (NIDC) released draft guidance on determining whether an ingredient qualifies as a new cosmetic ingredient. The consultation closed on October 25, 2026, and the document remains a draft. Companies should not treat it as final or effective guidance. See the NIDC consultation notice and REACH24H's detailed analysis of the draft criteria.

NIDC also published two trial mechanisms:

• The pre-submission consultation mechanism for cosmetics with new efficacy claims allows cosmetic registrants to request communication on key technical questions through the cosmetics review system before applying to register a product with a new efficacy claim. See the NIDC notice.

• The new cosmetic ingredient innovation guidance mechanism allows new ingredient registrants and filing persons to select a guidance approach according to their specific needs. NIDC will provide technical support and guidance to provincial drug regulators that have the relevant capabilities and provide related services. See the NIDC notice.

These mechanisms establish channels for technical communication and guidance. They do not replace applicable registration or filing requirements.

Product Updates Under the Revised Safety Standards

Announcement No. 99 addresses changes to ingredient lists, microbial and harmful-substance limits, and testing methods. The required steps depend on the type of change.

For products already registered or filed:

• Replacing or reducing an affected ingredient: If it is replaced with a matrix ingredient, such as a solvent or filler, or its amount is reduced, the registrant or filing person may explain the adjustment and conduct a safety assessment without repeating registration or filing tests. If the change may affect product efficacy, the company must conduct a new efficacy evaluation and update the product name, label or other relevant information based on the results.

• Changing a fragrance: The proposed fragrance must undergo a safety assessment. Supporting evidence must show that it meets relevant Chinese national standards or International Fragrance Association (IFRA) standards.

• Making other formula changes: The registrant or filing person must repeat the relevant registration or filing tests and conduct a safety assessment before submitting a change application.

• Addressing revised limits or test methods: Companies must assess existing products. If previous reports and assessment results meet the revised requirements, the product standard may be updated and the supporting materials retained for inspection. If they do not, the company may need to adjust production processes or quality controls and conduct the relevant tests again.

For products already undergoing registration or filing tests before the revised requirements take effect, the existing test reports may still be used. The announcement also allows certain adjustments to special cosmetics under technical review at the supplementary-material stage, subject to the conditions specified in the notice.

Import and Product-Category Updates

The NMPA's October notice on 45 non-compliant cosmetic batches cited issues including microbial counts, sunscreen-agent content and discrepancies between detected ingredients and the product label or registration technical requirements. See the NMPA notice.

Customs information published on October 20 listed 15 cosmetic batches refused entry in September, citing labeling deficiencies and discrepancies between goods and accompanying certificates. The listed products were returned or destroyed. These notices make consistency across product composition, labeling, registration information and shipment documents a practical market-access concern.

For toothpaste businesses, the Toothpaste Classification Catalogue (NMPA Announcement No. 100 of 2026) will take effect on May 1, 2027. It defines eight efficacy categories and corresponding claim wording. See the official announcement.

Impact and Actionable Advice

Overseas brands, ingredient suppliers and their China-based registrants or filing persons should:

• Verify ingredient status and intended function for each ingredient planned for use in China, and monitor for the final version of the new-ingredient guidance.

• Map products against the revised standards, including formulas, labels, safety assessments, specifications and test methods.

• Classify each proposed formula change before selecting a route. Ingredient replacement or reduction, fragrance changes and other formula changes have different testing and documentation requirements.

• Coordinate product updates with the China registrant or filing person, including responsibility for assessments, supporting records and any change application.

• Track the applicable date for each revision rather than assuming a single effective date applies to all changes.

• Check shipment documents against the actual goods and product records before export, particularly labels and registration or filing information.