China Expands Animal Testing Data Exemptions in Major Cosmetics Registration and Filing Reform

On July 29, 2026, China's National Medical Products Administration (NMPA) issued the "Announcement on Matters Related to Cosmetics Registration and Filing" (Announcement No. 70 of 2026), introducing eight measures to optimize cosmetics registration and filing procedures.

While the reforms streamline international launches, ingredient management, efficacy substantiation, and manufacturing changes, the expansion of toxicology report exemptions stands as the defining development for international cosmetics brands. By reducing administrative friction while reinforcing enterprise accountability, the NMPA is advancing a more risk-based, science-driven regulatory framework that further transitions China away from routine animal testing.

Expanded Toxicology Report Exemptions

Building on previous reforms that created exemption pathways for ordinary cosmetics, Announcement No. 70 extends this relief to select special cosmetics and new ingredient categories:

• Hair perm products
• Non-oxidative hair dyes
• Freckle-removing and whitening products that achieve their effect solely through physical coverage
• General cosmetics containing new cosmetic ingredients, excluding children's cosmetics

The inclusion of physically acting whitening products highlights the NMPA’s increasingly risk-based approach, distinguishing products that create visual coverage effects from those relying on biological activity.

Conditions for the Toxicology Report Exemption

This regulatory relief is not automatic. To qualify, manufacturers must meet specific compliance criteria:

• Quality Certification: Brands must hold a production quality management system certification or equivalent documentation issued by the competent government authority in the country or region of manufacture.
• Safety Evidence: The product's safety risk assessment must provide sufficient, scientifically sound evidence demonstrating product safety.

The announcement also authorizes the NMPA's cosmetics technical evaluation body to further expand the exemption through future technical guidance as scientific knowledge develops.

Companies should note that meeting China’s regulatory exemption criteria does not automatically satisfy third-party cruelty-free certification requirements, which often apply broader standards.

China Supports First Launches of International Cosmetic Products

Beyond animal testing reforms, Announcement No. 70 introduces greater flexibility for global product launches.

Previously, overseas applicants generally needed to demonstrate that products were already marketed in their country or region of origin before applying in China. Under the new policy, brands launching products first in China — or coordinating simultaneous global launches — may submit a first-launch commitment statement instead.

Applicants may also submit packaging artwork instead of finalized overseas commercial packaging, removing procedural delays that previously slowed synchronized market entry.

NMPA Expands Accepted Cosmetic Efficacy Evaluation Methods

The announcement broadens the range of acceptable methods for substantiating cosmetic efficacy claims, offering a major advantage for innovative products and emerging technologies.

Except for whitening, sunscreen, and anti-hair-loss claims, applicants may now use scientifically supported methods based on:

• International standards
• Industry standards
• Technical guidelines
• Validated company-developed methods

Simplified Cosmetic Ingredient Information Requirements

Announcement No. 70 significantly reduces upfront ingredient documentation requirements. Applicants generally need only identify the ingredient manufacturer, while supporting documentation must be retained internally for future inspection. The NMPA will also discontinue publication of ingredient submission codes.

Exception: Where the "Safety and Technical Standards for Cosmetics" or other applicable technical documents establish ingredient quality specifications, applicants must still submit relevant specifications or testing reports within the formula or safety assessment sections.

This shift reduces submission requirements but increases enterprise responsibility. Companies should maintain robust, audit-ready systems for managing supplier documentation, technical specifications, and safety data.

NMPA Allows Shared Safety and Efficacy Data for Similar Cosmetics

Previously, closely related products often required separate safety and efficacy evaluations despite only minor formulation differences. Announcement No. 70 introduces a data-sharing mechanism for similar formulations under the same brand and registrant or filer.

Shared Safety Testing for Similar Formulations

The new policy allows companies to select one representative product for:

• Microbiological testing
• Physicochemical testing
• Toxicological testing
• Human safety testing

Other similar products may rely on the same reports when formulation similarity is demonstrated, and the scientific basis for data sharing is justified.

For example, multi-shade lipstick collections that differ only in the permitted formulation variables (e.g., pigments, fragrances, pH adjusters, thickeners, pearlescent agents)  may no longer require separate toxicity testing for every SKU.

Caveat: If similar products are produced across different manufacturing facilities, microbiological and physicochemical testing must still be conducted separately due to environmental variables. Toxicological and human safety reports may continue to be shared where scientifically appropriate.

Shared Efficacy Evaluation Data

A similar approach applies for efficacy substantiation. Representative products may support efficacy claims for similar formulations following an equivalence assessment demonstrating that the shared data remain scientifically valid.

However, Whitening, sunscreen, and anti‑hair‑loss claims are also eligible for data‑sharing, but registrants must submit the full efficacy evaluation dossiers and formulation similarity explanations during registration (rather than merely keeping them on file for inspection).

Simplified Manufacturing Site and Responsible Person Changes

Announcement No. 70 also introduces further procedural simplifications for companies managing manufacturing changes and regulatory responsibilities in China.

Streamlined Manufacturing Transfers

The announcement reduces documentation requirements when registered or notified products transfer manufacturing locations.

Where the registrant or filer, product name, and formulation remain unchanged, and the applicable standards have not undergone substantial changes, companies may reuse existing:

• Toxicological reports
• Human safety reports
• Safety assessments
• Efficacy evaluation reports

Only microbiological and physicochemical testing must be repeated.

The policy applies to imported products moving to domestic production, adding domestic manufacturers, and domestic products transferring overseas production or adding overseas manufacturers.

Simplified Domestic Responsible Person Changes

The announcement also streamlines procedures for changing the domestic responsible person. Applicants no longer need to submit consent from the previous responsible person or legal documentation confirming the transfer.

Instead, they must provide:

• Authorization documentation and notarization
• A comprehensive list of affected products
• A formal commitment letter from the incoming responsible person accepting total regulatory accountability for all products already on the market

What Companies Should Do Next

Global brands planning to register or distribute cosmetics in China should immediately review their product pipelines against the updated framework. Priority actions include:

1. Audit Manufacturing and Supplier Compliance

Regulatory teams should review contract manufacturers’ government-issued quality management certifications or equivalent documentation before submission to ensure they meet NMPA expectations.

With ingredient submission codes no longer publicly available, companies must also strengthen internal documentation systems. Close coordination between domestic responsible persons and global suppliers will be essential to ensure technical specifications and safety dossiers remain complete and inspection-ready.

2. Implement Portfolio Data-Sharing Strategies

To benefit from the new shared testing provisions, R&D teams should identify representative flagship products and design testing strategies that allow related formulations — such as multi-shade color cosmetics — to demonstrate structural equivalence and reduce redundant testing.

3. Accelerate China-First and Simultaneous Launches

Brands pursuing China-first strategies or simultaneous global launches should align regional development and regulatory timelines to fully leverage the new commitment statement and artwork submission pathways. Submitting Chinese applications in parallel with — or ahead of — other major markets can eliminate the product launch delays traditionally associated with waiting for prior overseas commercialization.

Final Thoughts

By expanding toxicology exemptions, enabling data sharing for similar products, and simplifying registration procedures, the NMPA is reducing unnecessary regulatory barriers while giving companies greater flexibility in how they bring products to market.

While these rules drastically reduce time-to-market, they also shift full liability onto internal recordkeeping and raw material transparency. Brands must implement rigorous supply chain auditing and portfolio mapping to withstand sudden NMPA investigations.

If your company is planning to register or notify cosmetics in China, contact Cisema today to discuss how the latest NMPA reforms may affect your products and how Cisema can support your regulatory strategy.

Further Information

Explore Cisema’s services for cosmetic product registration in China.

Learn about Cisema’s services for cosmetic ingredient registration in China.

References

Announcement on Matters Related to Cosmetics Registration and Filing

Policy interpretation of the "Announcement of the National Medical Products Administration on Matters Related to Cosmetic Registration and Filing."