REGULATORY UPDATE
Animal testing has long been a key concern for international cosmetic brands entering China. Following the release of NMPA Announcement No. 70 of 2026, more cosmetic products may qualify for exemption from submitting toxicological test reports during registration or notification.
The announcement, effective from July 29, 2026, extends the exemption to selected special cosmetics and general cosmetics formulated with new cosmetic ingredients, provided that specified manufacturing quality and product safety conditions are met.
However, this is not a blanket exemption for all imported cosmetics. Eligibility still depends on the product category, intended users, manufacturing sites, formula and available safety evidence. Companies should therefore complete an eligibility assessment before establishing their testing and China cosmetic registration or notification strategy.
Quick Navigation
Jump to the key sections of this article.
Which Cosmetics May Qualify for the Exemption?
Under NMPA Announcement No. 70 of 2026, the following products may be exempt from submitting toxicological test reports:
Hair perming products;
Non-oxidative hair dye products;
Freckle-removing and whitening products that work only through physical covering;
General cosmetics formulated with new cosmetic ingredients, excluding children's cosmetics.
The inclusion of selected special cosmetics and general cosmetics using new cosmetic ingredients expands China's previous exemption scope.
Although the announcement is commonly described as expanding “animal testing exemptions,” its precise regulatory effect is an exemption from submitting product toxicological test reports. Other registration, notification, safety assessment and applicable testing requirements may still apply.
Special cosmetics must still complete registration, while general cosmetics are subject to notification or filing under China's Regulations on Supervision and Administration of Cosmetics.
What Conditions Must Be Met?
A product must meet both of the following conditions.
1. Government-issued manufacturing qualification
The manufacturing enterprise must have obtained a production quality management system qualification certificate issued by the competent government authority in its country or region.
For imported cosmetics, companies should confirm that the certificate:
Covers the relevant manufacturer and production site;
Applies to the product category concerned;
Is issued or recognized by the competent government authority;
Remains valid when the registration or notification dossier is submitted.
If several manufacturers or filling sites are involved, the qualification status of each relevant site should be reviewed. A product may be unable to rely on the exemption if a required site cannot provide acceptable documentation.
2. Sufficient product safety assessment
The product safety risk assessment must sufficiently confirm the safety of the finished product.
Depending on the formula and use scenario, the assessment may need to address ingredient safety, risk substances, exposure levels, product stability, preservative effectiveness and packaging compatibility.
The exemption does not reduce the registrant's or notifier's responsibility for product safety. Adequate evidence must still be available to support the cosmetic safety assessment.
Which Cosmetics Generally Remain Outside the Exemption?
The expanded exemption does not cover all products.
| Product or circumstance | Current position |
|---|---|
| Children's cosmetics | Excluded from the exemption for general cosmetics using new cosmetic ingredients |
| Oxidative hair dyes | Not included in the expanded scope |
| Anti-hair loss products | Not included |
| Sunscreen products | Not included |
| Whitening products acting through mechanisms other than physical covering | Not included |
| Cosmetics claiming a new efficacy | Not included |
| Manufacturer without acceptable government-issued quality certification | Generally unable to qualify |
| Relevant party subject to key regulatory supervision | May be unable to rely on the exemption |
General cosmetics using a new cosmetic ingredient may qualify under the 2026 announcement, but companies must still assess the ingredient's regulatory status, permitted use, available safety data and safety monitoring obligations. Further information is available on China new cosmetic ingredient registration and notification.
Can Similar Products Share Test Reports?
Announcement No. 70 also allows certain products with similar formula systems to share test reports. This is separate from the toxicological test report exemption.
For multiple products under the same brand and the same registrant or notifier, one representative product may be selected for microbiological and physicochemical testing, toxicological testing and human safety testing.
Other products may share the reports if the applicant:
Explains how the formula systems are similar;
Evaluates whether sharing the reports is scientifically reasonable;
Confirms that the products meet NMPA's similarity criteria.
The permitted differences are generally limited to specified ingredient groups, such as colorants, fragrances, pH adjusters, polymeric thickeners and pearlescent agents. Other ingredients and their concentrations, as well as the dosage form and method of use, should remain the same.
Where products are made at different production sites, separate microbiological and physicochemical testing is generally required for each site. Toxicological and human safety test reports may still be shared if the relevant conditions are met.
Can Existing Reports Be Reused After a Production-Site Change?
The announcement also simplifies the requirements when an existing imported cosmetic is transferred to production in China or a Chinese manufacturer is added.
Existing toxicological, human safety, safety assessment and efficacy evaluation reports may be reused if:
The registrant or notifier remains unchanged;
The product name remains unchanged;
The formula remains unchanged;
The implemented product standard has not substantively changed.
However, microbiological and physicochemical testing must be conducted again, and the original registration certificate or notification record must be submitted.
This is a report-reuse arrangement for production-site changes rather than a general animal testing exemption.
What Should International Brands Check?
Before planning product testing or submitting a dossier, brands should verify four points:
Product classification: Determine whether the product is a general cosmetic, special cosmetic or children's cosmetic.
Manufacturing qualifications: Check whether every relevant manufacturer or filling site has acceptable government-issued quality management documentation.
Formula and safety evidence: Review new cosmetic ingredient use, ingredient safety data and whether the product safety assessment can sufficiently confirm safety.
Applicable pathway: Distinguish between a toxicological test report exemption, similar-formula report sharing and report reuse following a production-site change.
A product-specific assessment should be completed before testing begins. Selecting an unsuitable pathway may result in unnecessary testing, dossier revisions or delays in market entry.
How REACH24H Can Help
REACH24H supports international cosmetic companies entering the Chinese market through:
Product classification and animal-testing exemption eligibility assessment;
Formula and ingredient compliance review;
Cosmetic safety assessment and data-gap analysis;
China cosmetic registration and notification support.
For product-specific support, contact REACH24H to assess the applicable testing and registration or notification pathway.
Conclusion
NMPA Announcement No. 70 of 2026 expands the scope of cosmetics that may qualify for exemption from submitting toxicological test reports. The change is particularly relevant to selected special cosmetics and general cosmetics using new cosmetic ingredients.
Nevertheless, the exemption remains conditional. Product category, intended users, manufacturing qualifications and the adequacy of the safety assessment must all be considered before determining the appropriate China registration or notification pathway.
