China's National Medical Products Administration (NMPA) has issued a series of clarifications and technical guidelines that directly impact how cosmetic labels are designed for imported products. Under the Cosmetic Labeling Management Measures (effective May 1, 2022, with full enforcement now in effect) and subsequent announcements, two of the most frequently misunderstood requirements are minimum font size for label text and the standardized naming of ingredients. Many importers continue to face customs holds and market surveillance rejections because their labels use incorrect ingredient names from the Inventory of Existing Cosmetic Ingredients (IECIC) or fail to meet the legibility standards. This guide consolidates NMPA‘s latest clarifications on font size and ingredient naming, providing practical examples and a compliance checklist for foreign cosmetic brands.
1. Minimum Font Size: ≥1.8mm for Simplified Chinese Characters
Under Article 18 of the Cosmetic Labeling Management Measures, the minimum font size for all simplified Chinese characters on the label (including warnings, ingredient list, and product name) is 1.8 millimeters in height. The NMPA has clarified that this measurement refers to the height of the lowercase Chinese characters (e.g., “一”, “中”) and applies to all mandatory label content. For packaging with a surface area of ≤20 cm², the minimum font size may be reduced, but not below 1.5 millimeters.
Common font size violations include:
- Using the same font size for Chinese characters as for English text, where the Chinese is smaller due to typeface design.
- Applying a 1.8 mm font but using a thin or light typeface (e.g., “light” weight) that is difficult to read – the NMPA expects bold or regular weight with clear strokes.
- Labeling curved surfaces where the effective printed character height is less than 1.8 mm due to distortion.
2. Exception for Miniature or Small Packaging
For cosmetic products where the primary display panel (or the largest surface area) is ≤20 cm² (e.g., lipstick bullets, small eyeshadow palettes, sample vials), the minimum font size may be reduced to 1.5 mm. However, the NMPA has clarified that this exception does not apply to the ingredient list if the packaging simply cannot accommodate the full ingredient list at 1.5 mm – in such cases, the ingredient list may be provided on a removable sticker label or on the outer carton, but the outer label must still comply with the 1.5 mm minimum. For products sold in a set (e.g., gift box), each individual item‘s label must meet the requirement; the box label alone is not sufficient.
3. Mandatory Use of IECIC Standardized Chinese Names for Ingredients
The most common labeling error leading to import rejection is the use of an unofficial or machine‑translated ingredient name that does not match the standardized name in the Inventory of Existing Cosmetic Ingredients (IECIC). Under Article 12 of the Cosmetic Labeling Management Measures, all ingredients must be listed using the standard Chinese name as specified in IECIC (or, for new ingredients, the approved filing name). INCI names alone are not sufficient; the Chinese name must appear.
Examples of correct vs. incorrect naming:
- Water – Correct: “水” (IECIC). Incorrect: “去离子水” (deionized water) unless specifically listed.
- Glycerin – Correct: “甘油”. Incorrect: “丙三醇” (propanetriol – the chemical name but not the IECIC entry).
- Butyrospermum parkii (shea butter) extract – Correct: “牛油果树果脂提取物” (as per IECIC). Incorrect: “乳木果油提取物” (unofficial translation).
The NMPA has also clarified that for botanical extracts, the standardized name must follow the form: “植物名称部分提取物” (e.g., “库拉索芦荟叶提取物” for Aloe barbadensis leaf extract). Common prefixes or suffixes such as “hydrolyzed”, “ferment”, “oil”, “water”, “powder”, “extract”, “filtrate”, “distillate”, “juice”, “meristem cell culture”, “callus”, “root”, “leaf”, “seed”, “flower”, “stem” are permitted only if they appear in the IECIC entry. If the IECIC entry does not specify a part (e.g., just “库拉索芦荟提取物”), you may not add “叶” (leaf) to the name.
4. Handling of Botanical Extracts and Nomenclature Discrepancies
In 2025-2026, NMPA conducted a systematic standardization of IECIC botanical names, updating entries that previously used outdated or inconsistent taxonomy. For example, “ERIOCAULON BUERGARIANUM FLOWER/STEM EXTRACT” was updated to the correct botanical spelling. Importers should verify that their label ingredient names match the exact IECIC entry, including any updates published on the NMPA website. If an IECIC entry contains a slash (e.g., “Flower/Stem”), the Chinese label must include both parts (花/茎). You cannot omit one.
For imported products where the foreign label uses a different plant species or part than the IECIC entry, you must use the IECIC name. The NMPA does not accept “similar to” or “equivalent to” substitutions. For example, if your product contains “Prunus amygdalus dulcis (sweet almond) oil” but IECIC lists “甜扁桃油” (sweet almond oil), that is acceptable. But if the species differs, you may need to reformulate or apply for a new ingredient filing.
5. Ingredient Concentration Labeling (Voluntary but Guided)
While not mandatory, the NMPA has clarified that if a manufacturer voluntarily labels the concentration of an ingredient (e.g., “含有10%烟酰胺” – contains 10% niacinamide), the declared value must be accurate, and the manufacturer must retain supporting test data. Misleading concentration claims (e.g., labeling “10%” but testing shows 8%) are considered false labeling and subject to penalties. This clarification is particularly important for “active” ingredients such as niacinamide, salicylic acid, or retinol.
6. Bilingual Labels and Foreign Language Prominence
Under Article 18, if the label includes a foreign language (including English, Japanese, Korean, etc.), the simplified Chinese text must be at least as prominent as the foreign language text. This means:
- Chinese font size cannot be smaller than the foreign language font size.
- Chinese cannot be printed in a less visible color or location (e.g., on a fold‑out flap while English is on the front).
- For mandatory content (ingredient list, warnings, product name), the Chinese version must appear directly on the package, not only on an insert.
A common violation is using a bilingual ingredient list where the Chinese is printed in a tiny font at the bottom of the label while the English INCI names are prominently displayed. Customs will reject such labels as non‑compliant.
7. New Child Safety Warning Requirement (Amendment No. 1 to GB 38598)
Under Amendment No. 1 to GB 38598-2020 (effective May 1, 2025), a new child safety warning is required for certain cosmetic products. Specifically, for antibacterial and bacteriostatic products (including antimicrobial wet wipes), the label must include the statement: “This product is not a drug and does not have therapeutic, nursing or health care effects.” For vaginal mucosal products, an additional warning is required: “Not for use in prevention of sexually transmitted diseases during sexual intercourse.” These warnings must be in boldface or have a font size larger than the “Directions for use” text. For imported cosmetics that fall under these categories (e.g., feminine hygiene washes, antibacterial facial cleansers), the warning must appear in simplified Chinese.
8. Common Rejection Scenarios and How to Avoid Them
Based on customs detention data, the most frequent label rejections related to font size and ingredient naming include:
- Chinese ingredient name not in IECIC: The importer translates “Tocopheryl Acetate” as “维生素E醋酸酯” when IECIC lists “生育酚乙酸酯”. Solution: always cross‑reference the IECIC database (publicly accessible on NMPA‘s website).
- Missing space between ingredient entries: The ingredient list must be clearly separated (by commas, semicolons, or line breaks). A continuous string of names without separation is invalid.
- Font size below 1.8 mm but packaging area >20 cm²: Some importers mistakenly believe that if the package is “small” but the surface area exceeds 20 cm² (e.g., a 50 mL tube has a label area >20 cm²), they can use 1.5 mm font. This is incorrect. Measure the actual label area.
- Foreign language more prominent than Chinese: e.g., English product name “Brightening Serum” in large gold letters, Chinese name “美白精华” in small black text. Both must be equally prominent.
- Missing child safety warning for antibacterial products: Importers of antibacterial hand washes, antimicrobial wet wipes, and feminine hygiene washes often omit the new warning text introduced by Amendment No. 1.
9. Practical Compliance Checklist for Imported Cosmetics Labels
- [ ] All simplified Chinese characters (mandatory content) have font height ≥1.8 mm (or ≥1.5 mm if display area ≤20 cm²).
- [ ] Ingredient list uses IECIC standardized Chinese names – verified against the NMPA online database.
- [ ] For botanical extracts, the exact IECIC name (including plant part) is used.
- [ ] Bilingual labels: Chinese is at least as prominent as foreign language (same font size, visibility, placement).
- [ ] For antibacterial/bacteriostatic products: required child safety warning present in boldface or larger font.
- [ ] Voluntarily labeled ingredient concentrations are accurate and supported by test data.
- [ ] All mandatory label elements (product name, registration/filing number, manufacturer, importer, ingredient list, net content, production date, expiry date, warnings) are present and in Chinese.
- [ ] Label is permanent (printed directly or durable sticker) – no removable hang tags for mandatory content.
Summary: NMPA has clarified that cosmetic labels must use simplified Chinese characters with a minimum height of 1.8 mm (1.5 mm for very small packaging), and that all ingredient names must exactly match the standardized names in the Inventory of Existing Cosmetic Ingredients (IECIC). Foreign language text cannot be more prominent than Chinese, and new child safety warnings apply to antibacterial products. Importers who audit their labels against IECIC, verify font sizes, and include mandatory warnings will avoid customs holds and market surveillance penalties. With full enforcement of the Cosmetic Labeling Management Measures now in effect, proactive compliance is the only safe path.