NMPA Strengthens Cosmetics Oversight with New CBD Testing Methods

On January 12, 2026, China’s National Medical Products Administration (NMPA) issued “NMPA Announcement No. 1 of 2026,” incorporating five testing methods — including the “Test Method for Six Ingredients Including Cannabidiol in Cosmetics” — into the “Safety and Technical Standards for Cosmetics (2015 Edition).”

While no new substance restrictions were introduced, the update equips regulators with standardized analytical tools, enabling consistent detection and enforcement.

Standardized Testing Methods Strengthen Regulatory Enforcement

Under the Cosmetics Supervision and Administration Regulation (CSAR) and its supporting framework, product registration, notification, and post-market surveillance must align with the Safety and Technical Standards for Cosmetics. These standards define both safety limits and official testing methods.

Previously, certain regulated or emerging substances lacked unified testing protocols, leading to inconsistent methodologies and limited comparability of results across laboratories. The addition and revision of five methods address these gaps by:

• Introducing methods for high-priority or emerging substances (such as CBD)
• Enhancing detection capabilities for known risk compounds (such as diethylene glycol)
• Updating legacy analytical techniques across over 100 ingredients

With standardized methods now in place, regulatory requirements become fully enforceable.

Key Technical Updates and Regulatory Implications

The newly introduced and revised methods have direct implications for international cosmetics companies, particularly in risk management, testing strategies, and supply chain oversight.

Cannabidiol (CBD) Testing Signals Active Market Surveillance

The introduction of a dedicated method for cannabidiol (CBD) — which remains unapproved for cosmetic use in China — marks a clear escalation in enforcement capability. With a validated detection method now in place, authorities can systematically screen products for both intentional use and trace contamination.

For international companies, this creates immediate exposure:

• Heightened enforcement risk: Imported products containing or potentially contaminated with cannabis-derived substances — including full-spectrum or broad-spectrum extracts — face increased likelihood of detection during inspections
• Stricter supply chain controls: Ingredients such as hemp seed oil must be verified to ensure cannabinoid impurities meet Chinese regulatory expectations, supported by test reports aligned with official methods
• Increased scrutiny of claims: Any product claims referencing cannabis may trigger targeted testing

Expanded Monitoring of Toxic Impurities Such as Diethylene Glycol

The addition of a diethylene glycol testing method reinforces regulatory attention on contamination risks.

As a known toxic impurity that may originate from raw materials like glycerin, its inclusion signals tighter control over upstream quality. Companies must ensure that impurity specifications are not only defined but verifiable under official methods.

Large-Scale Revisions to Existing Ingredient Testing Methods

Updates to testing methods covering more than 23 ingredients (including procainamide) and 124 ingredients (including 6α-methyl hydrocortisone) cover categories such as preservatives, UV filters, hair dyes, and whitening agents.

These updates may involve more advanced, sensitive, and specific analytical techniques, such as:

• Updated liquid chromatography conditions
• Introduction of mass spectrometry detection

This creates a practical challenge: existing test reports may no longer align with results generated under updated methods. Two consequences follow:

• Historical compliance data may not withstand future inspections
• Laboratories must rapidly upgrade capabilities, including method validation and instrumentation

Revision of General Principles for Physicochemical Testing

The revised “General Principles for Physicochemical Testing Methods,” effective earlier than the other updates, underpins all analytical procedures.

Changes to sample preparation, validation standards, and result reporting will require laboratories to revise internal systems.

Tight Timelines Require Early Action

The NMPA has defined a clear implementation schedule, requiring companies to act within tight timelines.

• July 1, 2026: Implementation of the revised General Principles for Physicochemical Testing Methods
• January 1, 2027: Implementation of the remaining four testing methods

Although early adoption is not required, it is encouraged for registration and notification testing. Submissions prepared using updated methods are more likely to align with regulatory review, reducing the risk of re-testing or delays.

Compliance Priorities for Overseas Cosmetics Companies

To adapt effectively, international manufacturers and brand owners should take a proactive and structured approach.

Reassess Product Formulations and Ingredient Risks

Companies should immediately review their portfolios to identify:

• Ingredients covered by the new or revised methods
• Potential exposure to CBD or cannabis-derived substances
• Raw materials with known impurity risks, such as diethylene glycol

Supplier documentation should be updated to include test reports aligned with, or comparable to, the new Chinese methods.

Upgrade Testing Strategies and Laboratory Readiness

Organizations must ensure that their testing partners are prepared for the transition. Key actions include:

• Confirming that partner laboratories have initiated method implementation and validation
• Planning internal capability upgrades where in-house testing is conducted
• Ensuring all future reports meet NMPA-recognized standards

Align Registration and Notification Timelines

Testing strategy should be closely integrated with regulatory submission planning.

For new product applications:

• Consider adopting new methods in advance of formal implementation
• Avoid reliance on legacy test data that may require re-testing

For products already on the market:

• Recognize that future inspections will apply updated methods
• Conduct internal risk-based re-testing where appropriate

Analyze Method Parameters to Understand Enforcement Thresholds

Detailed review of method parameters, such as limits of detection and quantification, is essential.

These technical thresholds directly indicate:

• Regulatory sensitivity to specific substances
• Acceptable “non-detectable” levels in practice

Understanding these parameters supports more accurate risk assessments and compliance decisions.

Final Thoughts: From Technical Update to Operational Pressure

For overseas companies, the risk is subtle but material. A formulation that appears compliant on paper can fail in practice if:

• Supplier data is not generated using comparable methods
• Detection limits are stricter than internal specifications
• Trace impurities — previously undetected — are now quantifiable

This is where most compliance breakdowns will occur — not in formulation design, but in the alignment between global testing practices and China’s specific analytical expectations.

The practical challenge is translating method updates into operational decisions: which products to re-test, which suppliers to re-qualify, and which data sets may no longer be defensible under inspection.

Cisema works at that exact intersection. We help you identify where your current data may not hold under NMPA methods, align your testing strategy with regulatory expectations, and ensure your submissions and products remain robust under inspection. For support in navigating these regulatory changes and ensuring continued compliance, contact Cisema today.

Further Information

Explore Cisema’s services for cosmetics registration and compliance in China.

References

NMPA Announcement on Incorporating Five Testing Methods, Including Methods for Six Ingredients Such as Cannabidiol, into the Safety and Technical Standards for Cosmetics (2015 Edition) (No. 1 of 2026)