China Chemical & Cosmetic Regulatory Update
On June 11, 2026, China’s Ministry of Ecology and Environment (MEE) released a draft revision to the Measures for the Environmental Management Registration of New Chemical Substances for public consultation. For overseas cosmetic companies exporting finished products to China, the most important potential change is the removal of cosmetics from the current product-based exemption wording.
China’s Ministry of Ecology and Environment issued the Letter on Publicly Soliciting Opinions on the Revision Draft on June 11, 2026, together with the Revision Draft for Public Comment.
If adopted as drafted, imported finished cosmetics containing substances not listed in China’s Inventory of Existing Chemical Substances in China (IECSC) may require closer ingredient-level new chemical substance compliance assessment, in addition to NMPA cosmetic product registration or notification. The public comment period ends on July 12, 2026.
For a broader chemical-sector analysis of the same Revision Draft, see REACH24H’s earlier insight: China MEE Proposes Major Revisions to New Chemical Substance Registration Measures.
Comment deadline: July 12, 2026
Overseas cosmetic brands should monitor the final text and assess whether China-bound formulas contain substances that may need IECSC status confirmation or further assessment under the MEE framework.
Quick Takeaways
NMPA compliance may not be enough. The draft raises the possibility that imported finished cosmetics may need additional substance-level screening under MEE rules.
IECIC status does not equal IECSC status. An ingredient listed in China’s cosmetic ingredient inventory may still require confirmation against China’s existing chemical substance inventory.
Imported cosmetics may be more exposed. The main practical impact may fall on overseas brands exporting finished cosmetic products to China rather than only on domestic raw material producers or importers.
Supply chain responsibility may become more complex. Overseas brands, ingredient suppliers, China importers and domestic responsible persons may need to clarify who performs substance screening or registration where applicable.
The draft is not final. Companies should avoid treating the current draft as a final legal requirement and should monitor the adopted text and implementing guidance.
Quick Navigation
What Changed | Imported Cosmetics | IECIC vs. IECSC | Ingredient Screening | Potential Impact | Enterprise Actions | How REACH24H Can Help
What Changed in the MEE Order No. 12 Draft?
The current Measures for the Environmental Management Registration of New Chemical Substances, commonly known as MEE Order No. 12, were issued in 2020 and came into force on January 1, 2021. Under the current rules, products such as pharmaceuticals, pesticides, veterinary drugs, cosmetics, food, food additives, feed, feed additives and fertilizers are listed as outside the scope of the Measures, except where they are converted for other industrial uses or used as raw materials or intermediates.
In the 2026 Revision Draft, this product-based exemption list no longer appears in the same form. Instead, the draft focuses on the environmental management registration of new chemical substances and lists narrower exclusions, such as certain substances stored in customs special supervision areas and exported without processing, chemicals used for scientific research and technical services, and radioactive chemicals.
For cosmetic companies, the key question may shift from whether a finished cosmetic product is exempt as a product category to whether the product contains an ingredient that qualifies as a new chemical substance in China. Companies that need broader support for the chemical substance framework may refer to REACH24H’s China REACH: New Chemical Substance Registration under MEE Order No. 12 service page.
Why Imported Cosmetics May Be More Affected Than Domestic Products
Under the current regulatory understanding, cosmetic raw materials that qualify as new chemical substances may already fall within the scope of MEE Order No. 12 when they are produced in China or imported into China. In many cases, this compliance responsibility may be handled by the ingredient manufacturer or importer before the ingredient enters the domestic supply chain.
The draft revision may create a different compliance concern for imported finished cosmetic products. For overseas brands, ingredients enter China as part of a finished product rather than as separately imported raw materials. If the final rule confirms that such products are no longer covered by the current product exemption wording, overseas cosmetic brands exporting to China may need to assess whether any formula ingredients are new chemical substances under the MEE framework.
This is why the potential impact is particularly relevant to EU, US, UK, Japanese and Korean cosmetic brands, as well as other overseas manufacturers and brand owners that use global formulations originally developed without China’s IECSC status as a primary design consideration. For finished product market access, brands should also review the requirements for China cosmetic product registration or notification.
IECIC vs. IECSC: Why Cosmetic Ingredient Status May Not Be Enough
China’s cosmetic regulatory system and chemical environmental management system use different inventories and serve different regulatory purposes.
IECIC — the Inventory of Existing Cosmetic Ingredients in China — is used to assess the eligibility of ingredients for the Chinese cosmetics market.
IECSC — the Inventory of Existing Chemical Substances in China — is used to determine whether a chemical substance is considered existing or new under China’s environmental management framework.
An ingredient may be acceptable from a cosmetic ingredient-use perspective but still require further chemical substance status assessment if it is not listed in IECSC or if its identity, CAS number, polymer status, botanical origin or composition requires case-by-case confirmation.
Therefore, overseas brands exporting cosmetics to China may need to build a two-layer screening process: cosmetic compliance under NMPA requirements and substance compliance under MEE requirements, where applicable. For cosmetic ingredient information submission, companies may also refer to China’s Cosmetic Ingredient Submission Code.
How Many Cosmetic Ingredients Could Need Further Screening?
Based on a preliminary CAS-number-based comparison between IECIC and the public version of IECSC in the provided source material, approximately 1,559 cosmetic ingredients listed in IECIC were not identified in the public IECSC dataset. In terms of ingredient categories, these substances encompass animal-derived, plant-derived, chemical, peptide, and fermentation-derived materials, among which plant-derived ingredients account for a significant proportion.
This figure should be treated as a preliminary reference only, not an official regulatory count. The actual number may vary because IECSC includes confidential entries, some substances may have multiple CAS numbers or broader substance identities, and certain ingredients may require expert identity confirmation.
Even so, the estimate suggests that overseas cosmetic brands may need to prepare for broader formula-level screening if the draft revision is adopted.
Potential Impact on Overseas Brands Exporting to China
If the draft is adopted in its current form, overseas cosmetic companies may face a more complex compliance review before exporting finished products to China.
The key impact is not limited to whether a cosmetic ingredient is allowed for use under China’s cosmetic regulatory system. Companies may also need to confirm whether the same ingredient is listed in IECSC or has completed new chemical substance registration under the MEE framework.
Additional pre-import screening: finished cosmetic products may need formula-level screening against both IECIC and IECSC.
Longer China launch timelines: products containing ingredients not listed in IECSC may require additional assessment before import.
Higher supplier documentation burden: overseas brands may need CAS numbers, substance identity information, IECSC status, MEE registration evidence or supplier declarations.
Confidentiality challenges: brands and ingredient suppliers may be reluctant to disclose full formulation or substance identity data to importers or local entities.
Responsibility allocation issues: overseas brand owners, China importers, domestic responsible persons and ingredient suppliers may need to clarify who performs the assessment or possible registration.
Portfolio review pressure: products already marketed or planned for launch in China may need to be reviewed if they contain ingredients potentially outside IECSC.
What Overseas Cosmetic Brands Should Do Now
Screen China-bound formulas against IECSC. Identify whether ingredients used in products exported to China are listed in IECSC, not only IECIC.
Prioritize high-risk ingredient categories. Pay particular attention to innovative functional ingredients, polymers, surfactants, botanical extracts, animal-derived materials and ingredients with unclear CAS identity.
Ask suppliers for China chemical compliance evidence. Request IECSC status confirmation, previous MEE registration evidence, substance identity information and available toxicology or ecotoxicology data.
Map responsibilities with China importers and domestic responsible persons. Clarify whether the overseas brand, ingredient supplier, China importer or domestic responsible person will be responsible for assessment, documentation or possible registration.
Assess impact on China launch timelines. Products planned for China launch should be reviewed early to avoid delays after NMPA registration or notification preparation has already started.
Consider submitting comments before the deadline. Companies and industry associations may consider providing technical comments before July 12, 2026, particularly on scope interpretation, confidentiality protection and coordination with cosmetics regulations.
Monitor the final rule and implementation guidance. The draft is still under public consultation, so companies should not treat the current text as a final legal requirement.
Brands using ingredients that may also fall under China cosmetic ingredient management should consider whether a separate China new cosmetic ingredient registration or notification/filing assessment is needed.
How REACH24H Can Help
REACH24H supports overseas cosmetic brands, ingredient suppliers and importers in assessing how China’s MEE Order No. 12 draft revision may affect market access and product launch strategies. Our chemical compliance and cosmetic compliance teams can assist with:
IECIC and IECSC screening for China-bound cosmetic formulas;
cosmetic ingredient and new chemical substance status assessment;
China cosmetic product registration or notification strategy;
China new cosmetic ingredient registration or notification strategy;
MEE new chemical substance registration pathway analysis;
data gap analysis and testing strategy review;
dossier preparation and submission support where applicable;
coordination among overseas brands, ingredient suppliers, China importers and domestic responsible persons;
ongoing monitoring of the final regulation and supporting guidance.
For overseas companies planning to export cosmetic products to China, an early ingredient portfolio review can help identify potential regulatory risks before product launch, import or NMPA submission timelines are affected.
Recommended Reading
China MEE Proposes Major Revisions to New Chemical Substance Registration Measures
China REACH: New Chemical Substance Registration under MEE Order No. 12
China New Cosmetic Ingredients Registration or Notification/Filing
Official Sources
Important Note: This article is based on the draft revision released for public consultation. The final regulatory text, implementation guidance, review practice and coordination with cosmetics regulations may differ from the current draft. Companies should refer to the official final text and seek professional assessment for specific products and ingredients.
