Major Breakthrough for Cosmetics Registration and Filing — Interpreting the Far-Reaching Impact of NMPA Announcement No. 70 on the OEM/ODM Industry
On July 29, 2026, the National Medical Products Administration (NMPA) officially issued the "Announcement on Matters Concerning Cosmetics Registration and Filing" (2026 No. 70), introducing eight optimization measures in one go, directly targeting key bottlenecks in the cosmetics registration and filing process. This is another substantive implementation in the registration and filing field following the "Opinions on Deepening Cosmetics Regulatory Reform and Promoting High-Quality Industry Development" (Guo Yao Jian Zhuang [2025] No. 18) issued in November 2025.
For cosmetics OEM/ODM companies, the weight of this announcement far exceeds that of a general policy interpretation.
I. Shared Data for Products with Similar Formulations: A Cliff-Like Drop in Testing Costs
The most direct benefit for OEM/ODM comes from the sharing of data among products with similar formulation systems.
The announcement clarifies: For products under the same registrant/filer and the same brand, where the formulations differ only in the types and amounts of colorants, fragrances, pH adjusters, high-molecular polymer thickeners, and pearlescent agents, while all other ingredients, dosage forms, and usage methods are identical, one representative product may be selected for the full battery of tests, and the other products may directly share the testing data.
What does this mean for us?
Anyone in the OEM/ODM business knows that when you change the shade of the same serum, adjust the fragrance, or tweak the thickener ratio, the formulation system essentially remains unchanged. But previously, every shade and every minor formulation adjustment required separate microbiological testing, toxicology tests, and efficacy evaluations — costing over a hundred thousand yuan and three to four months per round. Now, once one representative product completes testing, other similar products can directly share the data.
Categories such as lipstick, blush, eyeshadow, and perfume are most affected. If a brand makes 10 shades, previously it needed 10 sets of tests; now one set suffices. R&D costs drop significantly, and product iteration speed accelerates noticeably.
But note one prerequisite: the scope for determining "similar formulation systems" has clear boundaries. The variables listed in the announcement are limited to five categories — colorants, fragrances, pH adjusters, high-molecular polymer thickeners, and pearlescent agents — while the types and amounts of all other core ingredients must be identical. "Similarity" beyond this scope cannot be directly shared. Companies need to strictly evaluate whether their products truly meet the standard of "similar formulation systems" based on the definition.
II. Cancellation of Raw Material Reporting Codes: No Longer Held Hostage by Raw Material Suppliers
This is the measure that has drawn the strongest reaction from the industry in this reform.
Previously, raw material safety information had to be submitted by raw material suppliers through a dedicated platform to generate a reporting code, which brand owners needed to complete product registration and filing. Once a supplier failed to cooperate — especially foreign suppliers with limited understanding of or slow response to the new regulations — the brand's entire product launch process would be stalled.
The new announcement clarifies: When registering or filing a product, there is no need to submit raw material safety information files or raw material reporting codes; only the name of the raw material manufacturer needs to be filled in, and the relevant materials are to be archived by the company itself for future inspection.
From "code required" to "name only," from "platform review" to "company archiving" — this is not just process simplification; it is a shift in regulatory philosophy: returning primary responsibility to companies and minimizing administrative costs.
For OEM/ODM companies, this means:
- The time window from project initiation to filing for new products is significantly shortened
- Projects are no longer stalled because a raw material supplier delays issuing a reporting code
- Raw material switching becomes more flexible, and supply chain response speed improves
Of course, canceling the reporting code does not mean relaxing raw material safety management. Where technical documents such as the "Safety and Technical Standards for Cosmetics" have requirements, raw material quality specifications or inspection reports must still be submitted as required. The safety baseline has not been loosened.
III. Reduction of Animal Testing: Aligning with International Standards and Facilitating Global Expansion
The announcement expands the scope of animal testing reduction from ordinary cosmetics to:
- Hair styling products among special cosmetics
- Non-oxidative hair coloring products
- Spot-fading and whitening products with purely physical coverage effects
- Ordinary cosmetics using new raw materials (excluding children's cosmetics)
Conditions for the reduction: The manufacturer must have obtained relevant qualification certificates for its production quality management system issued by the competent government authority of the country (region) where it is located, and the product safety risk assessment results must be sufficient to confirm product safety.
The significance of this adjustment goes far beyond saving R&D costs. The EU has long banned animal testing for cosmetics. This reduction aligns with the internationally recognized 3R principle (Replacement, Reduction, Refinement) and removes key technical trade barriers for Chinese cosmetics exports to the EU and other markets.
For companies engaged in cross-border OEM/ODM, this is a clear signal: China's cosmetics regulation is aligning with international standards, and compliance barriers for domestic brands going global are gradually decreasing.
IV. Independent Selection of Efficacy Evaluation Methods: Innovation Space Opens Up
Except for spot-fading and whitening, sun protection, and anti-hair loss efficacy, the announcement allows companies to independently choose industry standards, international standards, technical guidelines, or validated in-house methods to conduct efficacy claim evaluation tests.
What does this mean for the industry?
Previously, efficacy evaluation methods were "one-size-fits-all" — regardless of the efficacy claim, a designated method had to be used. Now, except for special efficacy claims (spot-fading and whitening, sun protection, anti-hair loss), companies can choose the most suitable testing method for other efficacy claims (such as moisturizing, repairing, anti-wrinkle, soothing, etc.) based on product characteristics.
This gives companies greater room for innovation and promotes the iterative upgrading of efficacy evaluation methods themselves. Enhancing the industry's technological competitiveness from the source — this is the deeper logic behind regulatory reform.
V. Encouraging Global First Launches of International New Products in China: New Opportunities for Cross-Border Cooperation
For international new cosmetics products launching in China for the first time or simultaneously with China, only a commitment statement is required, and the submission of proof of prior market authorization documents is waived.
This breaks the traditional "launch elsewhere first, then enter China" path for international new products. For companies engaged in cross-border OEM/ODM, this may bring new cooperation opportunities — international brands will be more willing to make China their launch market, and domestic contract manufacturing and cooperation demand will increase accordingly.
VI. Simplified Production Site Changes and Domestic Responsible Person Changes
The announcement also simplifies two administrative procedures:
Cross-border production site changes: For already registered or filed products intended to transfer production sites (from imported to domestic or domestic to imported), if the formulation remains unchanged and the standards have not undergone substantive changes, toxicology test reports, human safety test reports, safety assessment reports, and efficacy evaluation reports may be shared, with only microbiological and physicochemical testing required to be redone.
Domestic responsible person changes: Procedural materials such as the informed consent letter from the original domestic responsible person are no longer required; only the notarized authorization letter, product list, and commitment letter need to be submitted.
These two adjustments may appear to be administrative optimizations, but their practical impact on companies is significant. The production site change cycle is compressed from several months to a few weeks, and domestic responsible person changes are no longer held up by the cooperation level of the original responsible person — companies' supply chain flexibility and commercial autonomy are noticeably improved.
VII. Practical Recommendations for OEM/ODM Companies
1. Immediately review the current project list: Identify which products fall within the scope of "similar formulation systems" and which can first undergo testing on a representative product with other products sharing the data. Prioritize cosmetics, fragrances, and multi-shade products within the same series to benefit from the policy advantages.
2. Re-evaluate the raw material reporting process: After the cancellation of reporting codes, companies need to establish an internal archiving and inspection system for raw material safety information. Although the materials do not need to be submitted, they must be retained on file, as the NMPA may conduct spot checks at any time.
3. Pay attention to the applicable scope of animal testing reduction: If products involve categories such as hair styling, non-oxidative hair coloring, or spot-fading and whitening with physical coverage, assess whether they meet the reduction conditions. GMP certificates and safety risk assessment reports are prerequisites.
4. Make good use of the choice in efficacy evaluation methods: Except for spot-fading and whitening, sun protection, and anti-hair loss, other efficacy claims can use testing methods better suited to product characteristics. It is recommended to fully communicate with testing institutions to select solutions that are lower in cost, shorter in cycle, and more scientifically robust.
5. Proactively seize cross-border cooperation opportunities: The policy benefit of first launches of international new products in China means cross-border OEM/ODM demand may increase. Companies with cross-border business can proactively connect with international brands to seize the first-mover advantage.
Conclusion
The core logic of the eight measures in this announcement is: Without lowering the safety baseline, use regulatory "subtraction" to exchange for corporate innovation "addition."
For OEM/ODM companies, this is not simple process optimization — it is a change in the industry's competitive landscape. Whoever adapts to the new regulations faster and leverages policy benefits more efficiently will take the initiative in the next round of competition.
Weipeptide Group will continue to monitor the implementation details of the policy and provide clients with compliant and efficient product development services.
Reference to Original Policies:
- NMPA "Announcement on Matters Concerning Cosmetics Registration and Filing" (2026 No. 70)
- NMPA "Opinions on Deepening Cosmetics Regulatory Reform and Promoting High-Quality Industry Development" (Guo Yao Jian Zhuang [2025] No. 18)
*This article was published on July 30, 2026, and represents the policy interpretation as of the date of publication. In the event of subsequent policy adjustments, the latest announcements from the NMPA shall prevail.*
