New Cosmetic Testing Requirements in China Effective July 2025

Starting July 1, 2025, five new cosmetic testing methods will become mandatory for all products registered, filed, or inspected in China. These regulatory updates, issued by the NMPA, required international manufacturers to align with revised safety standards to maintain or gain market access. The changes may impact product formulations, testing protocols, and documentation requirements. Companies are advised to begin technical and procedural assessments promptly to ensure full compliance by the enforcement date.

Overview of the New Testing Methods

Three new testing methods have been added:

1. the "Testing Method for Azelaic Acid and Its Salts in Cosmetics,"
2. the "Testing Method for Phenacetin in Cosmetics," and
3. the "Testing Method for Hydroxydecanoic Acid in Cosmetics."

These methods will be directly incorporated into the Technical Specifications for Cosmetic Safety (2015 Edition).

In addition, there are two revised testing methods, which will replace the existing methods:

1. the "Testing Method for Asbestos in Cosmetics" and
2. the "Testing Method for Glucuronic Acid and 14 Other Ingredients in Cosmetics,"

Implementation Date and Compliance Timeline

All new and revised testing methods will take effect on July 1, 2025. From that date, all cosmetics registered, filed, and subject to sampling inspections in China must adopt these new testing methods. For international companies, this means that they need to adjust product formulations and production processes before the compliance deadline to ensure that their products meet the new testing standards.

Impact on International Companies

• Product Formulation Adjustments: Companies may need to re-evaluate and adjust product formulations to meet the new testing standards. Products containing ingredients such as azelaic acid and its salts, phenacetin, and hydroxydecanoic acid may require formulation optimization.

• Quality Control Process Update: Companies should update their quality control processes to ensure that products comply with the new testing methods during production. This may involve updating laboratory equipment, training staff, and improving quality management systems.

• Registration and Filing Preparation: International companies planning to enter the Chinese market need to ensure that their products meet the new testing methods and submit corresponding test reports during the registration and filing process. Companies already selling products in the Chinese market will need to re-evaluate existing products to ensure ongoing compliance.

Strategies for International Companies

• Keeping Up with Regulatory Changes: Closely monitor the latest regulations and guidelines issued by the NMPA to stay informed about policy changes. Companies can keep up to date by subscribing to official announcements, attending industry seminars, or collaborating with professional consulting firms.

• Conducting Internal Assessments: Assess existing products to determine which ones may be affected by the new testing methods. Develop detailed rectification plans for affected products, including formulation adjustments and updates to quality control processes.

• Seeking Professional Support: Collaborate with professional regulatory consulting firms to obtain the latest regulatory interpretations and compliance advice. Professional firms like Cisema can provide regulatory consulting, registration and filing guidance, and optimization of quality control processes to help companies smoothly transition to the new regulatory requirements.

Evolution of China's Cosmetic Regulatory Framework

• Improvement of the Regulatory System: In recent years, China has continuously improved its cosmetic regulatory system. From the Regulations on the Supervision and Administration of Cosmetics to the Technical Specifications for Cosmetic Safety (2015 Edition), and now the addition of these new testing methods, regulatory requirements have become increasingly strict and detailed.

• Alignment with International Standards: China is gradually aligning its cosmetic regulation with international standards. The newly added testing methods are similar to internationally accepted testing standards, reflecting China's trend towards internationalization in cosmetic safety regulation.

• Shift in Regulatory Focus: The regulatory focus is shifting from macro-management to micro-details, with greater emphasis on quality control and risk management throughout the entire product lifecycle.

Align Quality Control with NMPA

The five new cosmetic testing methods announced by the NMPA will have a profound impact on China's cosmetic market. International companies need to pay close attention to these changes, promptly adjust product formulations and quality control processes, and ensure that their products meet the new testing standards. By collaborating with professional consulting firms, companies can better cope with regulatory changes and seize opportunities in the Chinese market.

Further Information

To read the original article issued by the NMPA for five new cosmetic testing methods will become mandatory for all products, please click here.

If you are an international cosmetic manufacturer with questions about how the new testing methods affect your product compliance or how to prepare for the updated registration requirements in China, please contact Cisema.

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