China Cosmetics Registration Reform Cuts Dossier Burdens

The measure is dated 28 July and took effect on publication. Earlier NMPA documents yield where they conflict with Announcement No. 70. International cosmetic products launched first in China, or simultaneously in China and another market, may use a declaration instead of proof that the product is already sold in the registrant’s or manufacturer’s country. A design drawing may be used for the overseas sales packaging.

Raw Material Safety Files Move To Company Retention

Under the China cosmetics registration changes, registrants and filing parties no longer routinely enter raw material safety files or submission codes. They enter the raw material manufacturer’s name and retain the supporting information for inspection.

Where the Cosmetic Safety Technical Specification or another technical document requires a quality specification, the business must still provide that specification or a test report in the formula or safety assessment materials. NMPA will no longer publish raw material submission codes. Changes to a material manufacturer or quality specification for an existing product still require maintenance or a formal variation under the applicable dossier rules.

This shift makes supplier governance more important, not less. Brands should confirm audit rights, version control, retention periods, change notification and rapid access to ingredient evidence before simplifying submissions.

Animal Testing And Data Reuse Gain Defined Flexibilities

Specified perming products, non-oxidative hair dyes and physically acting whitening products may qualify for a toxicology-report exemption. Ordinary cosmetics using new ingredients may also qualify, except children’s cosmetics. In each case, the manufacturer must hold qualifying government-issued good manufacturing practice evidence and a safety assessment must fully support safety.

Companies with similar formula systems under the same brand may reuse certain microbiological, physicochemical, toxicological, human-safety and efficacy data, subject to representative-product, site and equivalence conditions. Products made at different sites still require separate microbiological and physicochemical testing for representative products.

China cosmetics registration teams should update templates, testing strategies and responsibility matrices immediately. The announcement also simplifies changes of domestic responsible person and widens acceptable efficacy-testing methods for claims other than whitening, sunscreen and hair-loss prevention, where adequate scientific support exists.

Summary

China’s Announcement No. 70 immediately simplifies cosmetics and toothpaste registration while keeping safety accountability with businesses. Brands should redesign dossier workflows, strengthen supplier evidence retention, reassess animal-testing exemptions and validate data-reuse conditions. Existing products also need controlled updates when raw material manufacturers or specifications change after the reform takes effect.