Definition: what the 2025–2026 cosmetics reforms actually change
The "2025–2026 China cosmetics reforms" are a two-step deregulation package from the National Medical Products Administration (NMPA) that lowers the cost and time of bringing both imported and domestic cosmetics to market — without lowering safety standards. Step one is a strategic Opinion (24 reform measures); step two is an implementing Announcement (eight concrete measures) that brands can act on today.
The headline wins for an overseas brand: you can now launch a new product in China before it sells anywhere else, you may skip animal testing on more product types, and the paperwork for filing and registration got lighter. Below is the precise, sourced detail — and where the old rules still apply.
The two documents, in order
China's cosmetics regime sits under the Cosmetics Supervision and Administration Regulation (CSAR, 化妆品监督管理条例), in force since 1 January 2021, and its implementing Administrative Measures for Cosmetics Registration and Filing (化妆品注册备案管理办法). Every reform below works within that framework.
1. The Opinion — 国药监妆〔2025〕18号. Published 17 November 2025, this 24-measure policy paper (full text on gov.cn) set the direction: encourage international new products to launch in China first, accelerate animal-testing waivers (measure 23), and simplify registration/filing data. It is the "why"; the Announcement is the "how."
2. The Announcement — 2026 No. 70. Issued 28 July 2026 and effective 29 July 2026 (full text on nmpa.gov.cn), it turns the Opinion into eight operational measures. This is the document your regulatory affairs team will actually apply.
Measure 1 — "China-first launch" (中国首发): no more overseas-sales proof
Before this reform, an imported cosmetic had to show it was already marketed in its country of origin or production before China would register or file it. Obtaining that proof typically took one to two months, which is why many global launches reached Chinese consumers later than everyone else.
Under Announcement 2026 No. 70, an international new product that launches first in China — or simultaneously with other markets — can instead submit a commitment declaration of China-first launch and skip the overseas-sales proof entirely. Even the production-country sales packaging can be submitted as a design drawing. Industry commentary (quoted in China Pharmaceutical News) estimates this can bring a global launch to China roughly six months earlier.
Practical read: if your global launch calendar puts China on the list, you no longer have to ship and sell a batch abroad first just to satisfy Chinese paperwork.
Measure 2 — expanded animal-testing waivers
China never instituted a blanket animal-testing ban, but the exemption has been widening:
- Since 1 May 2021: imported general cosmetics can be exempt from mandatory animal testing if conditions are met — a home-country GMP/quality-management certificate, a complete safety assessment, and the product is not intended for infants or children.
- From 29 July 2026: the waiver extends to certain special cosmetics — perming products, non-oxidative hair dye, and spot-whitening products with only physical covering action — and to ordinary cosmetics that use new raw materials (excluding children's cosmetics), provided the manufacturer holds a home-country quality-system certificate and the safety risk assessment fully confirms safety. NMPA can widen the scope later via technical guidelines.
What this does not change: most special-use cosmetics (sunscreen, whitening with active agents, hair dye beyond the listed types, anti-hair-loss) and children's cosmetics still require toxicology data. Confirm per SKU.
Measures 3–8 — the "filing relief" package
The rest of Announcement 2026 No. 70 is about cutting redundant work:
- Raw-material data simplified (3): at filing/registration you no longer fill in each raw material's safety dossier and submission code — just the manufacturer name; the rest is kept on file by the enterprise. NMPA no longer publishes the submission codes.
- Shared safety data for similar formulas (4): within one brand, formula-similar products can use a single representative product's microbial, physicochemical, toxicology and human-safety test reports, with a similarity justification.
- Broader efficacy-claim methods (5): except for spot-whitening, sunscreen and anti-hair-loss, brands may choose industry/international standards, technical guides, or validated in-house methods for efficacy claims (with scientific basis).
- Shared efficacy data (6): formula-similar products can also share efficacy-claim evaluation data, with equivalence justification.
- Easier cross-border production-site transfers (7) and simplified responsible-person changes (8): changing your domestic responsible person (境内责任人) now needs only an authorization, a product list and a commitment letter — no outgoing responsible person's consent or court documents.
The responsible person still matters
The domestic responsible person (境内责任人) requirement under CSAR is unchanged for standard registration and filing: a foreign brand must still appoint a China-based entity to lodge filings, monitor adverse events and act as the local contact. What changed is only the change procedure (measure 8). Budget for appointing a competent responsible person — it is one of the most consequential choices you make.
Where this meets your channel decision
These reforms ease the general-trade and domestic-store path (full NMPA filing/registration, Chinese labels, a responsible person). They do not replace the leaner 1210 cross-border route: most cosmetics sold through Tmall Global, JD Worldwide or Douyin cross-border still enter under a simplified positive-list regime without full NMPA filing. For a first market test, 1210 remains the lowest-risk start; the 2025–2026 reforms make the scale-up to a domestic store materially faster and cheaper.
See our deeper guide on NMPA filing vs. registration and cross-border vs. general trade, the 1210 bonded import model, and importing via a Hong Kong trading entity as the importer-of-record alternative to forming a WFOE.
How GOODSINFINITE supports a beauty entry under the new rules
- Channel sequencing. We map whether your SKUs should enter via 1210 first or go straight to general trade, and we pre-screen claim language and category (general vs. special) before anything ships.
- Responsible-person and filing support. We coordinate the China responsible person, the dossier, and the new China-first-launch or animal-testing-waiver path where your products qualify.
- Hong Kong importer of record. GOODSINFINITE TRADE LIMITED imports under bond — no WFOE needed for a first 1210 test.
- Five-city bonded fulfilment for 1–3 day domestic delivery, plus Douyin cross-border livestream and RedNote (Xiaohongshu) seeding built for beauty audiences.
The 2025–2026 reforms reward brands that move fast: launch in China first, lean on the expanded testing waivers, and let the lighter filing regime cut your time-to-shelf. Pair that with a 1210 test to prove demand before you commit to a domestic store.
FAQ
Do imported cosmetics still need to be sold in their home country before entering China? Not for China-first launches. Under NMPA Announcement 2026 No. 70, international new products launching first in China (or simultaneously worldwide) can submit a China-first-launch commitment declaration and skip the proof of overseas sales — previously a one-to-two-month delay.
Has China banned animal testing for cosmetics? No blanket ban. Imported general cosmetics have been exempt since May 2021 if conditions are met; the 2026 Announcement extends the waiver to certain special cosmetics (perming, non-oxidative hair dye, physical-cover whitening) and new-ingredient ordinary cosmetics (excluding children's), with conditions. Most special-use and children's products still need toxicology data.
What changed for imported cosmetics in 2025–2026? Two documents: the 24-measure Opinion (国药监妆〔2025〕18号, 17 Nov 2025) set direction, and Announcement 2026 No. 70 (effective 29 Jul 2026) delivered eight measures — China-first launch, expanded testing waivers, simplified raw-material data, shared safety/efficacy data, broader efficacy methods, easier responsible-person changes.
Do I still need a China responsible person? Yes, the CSAR requirement remains for registration and filing. But changing the responsible person is now simpler — no outgoing consent letter or court documents, just an authorization, product list and commitment letter.
Does 1210 cross-border still avoid full NMPA filing? Yes. Cross-border (1210) retail still uses a simplified positive-list regime; the reforms primarily ease the general-trade and domestic-store path. They solve different problems and can be used together.
Sources
- National Medical Products Administration (NMPA) — Opinion on Deepening Cosmetic Regulatory Reform to Promote High-Quality Industry Development (国药监妆〔2025〕18号), published 17 November 2025: gov.cn
- National Medical Products Administration (NMPA) — Announcement on Matters Concerning Cosmetic Registration and Filing (2026 No. 70), effective 29 July 2026: nmpa.gov.cn
- China Pharmaceutical News (中国医药报, NMPA's official newspaper) — industry analysis of the 2026 Announcement and 2025 market-size data, August 2026: cnpharm.com
- NMPA — Cosmetics Supervision and Administration Regulation (CSAR, 化妆品监督管理条例) and the Administrative Measures for Cosmetics Registration and Filing: nmpa.gov.cn
- Beijing Municipal Medical Products Administration — Q&A on Announcement 2026 No. 70 optimisation measures: yjj.beijing.gov.cn