China NMPA Adds Black Ginseng Extract to IECIC in Third Adjustment

On January 4, 2026, the National Medical Products Administration (NMPA) issued a notice announcing the third dynamic adjustment to the “Inventory of Existing Cosmetic Ingredients” (IECIC). The update formally incorporates black ginseng extract, hydrolyzed sodium hyaluronate zinc, and galactomannan into the IECIC, shifting their regulatory status from “new cosmetic ingredients” to “existing ingredients” under China’s cosmetics regulatory framework.

This adjustment establishes a more efficient regulatory pathway for domestic and international companies seeking to use these ingredients in cosmetic products for the Chinese market.

Regulatory Framework Governing Cosmetic Ingredients in China

Under the “Cosmetics Supervision and Administration Regulation,” cosmetic ingredients are categorized as either “existing ingredients” or “new ingredients” based on their inclusion in the IECIC. Since its initial release in 2021, the January 2026 notice represents the third formal update under this system, reflecting responsiveness to technological innovation and market demand.

Existing Ingredients Listed in the IECIC

Ingredients listed in the IECIC are considered to have a documented history of use. When manufacturers incorporate these substances into cosmetic products, they are only required to complete finished product registration or filing procedures.

This pathway is comparatively streamlined and does not require separate new ingredient registration or filing.

New Cosmetic Ingredients and Filing Requirements

Ingredients not listed in the IECIC are classified as “new cosmetic ingredients.” These substances must undergo safety assessment and registration or filing in accordance with:

“Cosmetics Supervision and Administration Regulation”
“Provisions on the Administration of Registration and Filing Dossiers for New Cosmetic Ingredients”

The new ingredient process often requires several months or longer, particularly for high-risk ingredients, and includes ongoing post-filing safety monitoring obligations.

Key Changes Introduced in the Third IECIC Adjustment

Although limited to three ingredients, the adjustment highlights important compliance trends within China’s cosmetics regulatory system.

This section outlines the substantive changes and their practical implications.

Formal Incorporation of Three Ingredients

Under this adjustment, black ginseng extract, hydrolyzed sodium hyaluronate zinc, and galactomannan are formally incorporated into IECIC Part I.

Each ingredient also aligns with prevailing formulation trends in the cosmetics industry:

Black ginseng extract — a modern derivative of a traditional botanical ingredient with growing use in functional skincare.
Hydrolyzed sodium hyaluronate zinc — an innovative hyaluronic acid derivative combining moisturizing and soothing properties.
Galactomannan — a plant-derived polysaccharide consistent with clean beauty and natural formulation trends.

From a regulatory perspective, their formal inclusion produces clear compliance consequences.

New ingredient registration or filing is no longer required.
Companies may incorporate these substances directly into cosmetic formulations, subject to finished product registration or filing.

For overseas manufacturers, this change reduces regulatory lead time and overall compliance costs when entering the Chinese cosmetics market.

Notably, these ingredients had previously been “managed as existing ingredients.” For example, black ginseng extract — as a modern application of a traditional medicinal material — had existed in a regulatory gray area. Their formal incorporation into the IECIC following official review establishes a clearer regulatory precedent and demonstrates the practical application of the IECIC dynamic adjustment mechanism.

Standardization of Chinese and INCI Names

The notice also standardizes the Chinese names and INCI/English names of the relevant ingredients and revises certain technical remarks.

Although primarily administrative, this harmonization carries concrete compliance benefits:

It reduces discrepancies between overseas product documentation and Chinese regulatory filings.
It minimizes customs clearance risks caused by inconsistent naming.
It facilitates smoother cross-border trade and labeling alignment.

For companies engaged in China cosmetic registration or filing, consistent ingredient nomenclature is critical to avoid rejection or supplementary documentation requests.

Strategic Compliance Actions for Affected Companies

With the formal inclusion of these ingredients in the IECIC, companies should take coordinated steps to align compliance processes with updated regulatory expectations. A structured internal review will help ensure that regulatory, technical, and commercial strategies remain aligned.

Review Formulations and China Market Plans

As an initial step, manufacturers should reassess existing product portfolios and development pipelines to identify whether the newly incorporated ingredients are currently used — or could be strategically introduced — in formulations intended for the Chinese market.

This review should cover:

Existing product formulations
R&D pipelines
China market entry strategies

Companies already using these ingredients in overseas markets should evaluate the feasibility of introducing relevant products into China, taking into account documentation readiness, supplier qualifications, and supply chain compliance.

Update Technical Dossiers and Safety Information

Following strategic assessment, technical documentation should be updated accordingly. Although IECIC inclusion simplifies ingredient classification, it does not remove safety and filing obligations.

Companies must ensure that:

Cosmetic ingredient safety information files are complete and compliant.
Product formulation dossiers reflect standardized ingredient names.
Labels and technical materials align with current regulatory terminology.

Failure to implement timely updates may result in filing delays or compliance findings during regulatory review or post-market inspection.

Establish Ongoing Regulatory Monitoring Mechanisms

China’s cosmetics regulatory framework continues to develop, with periodic updates to ingredient classifications and technical standards that may directly affect product filings and market access.

To manage these changes efficiently, international manufacturers may consider partnering with a specialized regulatory firm such as Cisema. Through structured monitoring of NMPA announcements, IECIC dynamic adjustments, and revisions to cosmetic safety technical standards, companies can maintain continuous visibility over regulatory developments.

This approach supports timely compliance updates and enables manufacturers to adjust market strategies in a controlled and predictable manner.

Outlook for China’s Cosmetics Regulatory Environment

The third IECIC adjustment illustrates how Chinese regulators are refining the balance between encouraging innovation and maintaining safety oversight.

For international companies, the development provides a streamlined compliance pathway for certain functional and plant-based ingredients, as well as greater clarity in ingredient classification standards. At the same time, product registration, safety assessment, and labeling compliance obligations remain fully applicable.

Accordingly, timely regulatory interpretation and precise dossier preparation remain essential to capitalizing on new market opportunities. Whether you are an ingredient supplier, manufacturer, or brand owner, contact Cisema for support in navigating NMPA cosmetic ingredient compliance, IECIC assessments, and China cosmetic registration strategies.

Further Information

To learn more about how Cisema supports international manufacturers and brand owners in navigating China’s cosmetics regulatory framework, explore Cisema’s cosmetics registration services for the Chinese market.