For international cosmetic brands selling into China, the Chinese label is not just a translation – it is a legal document that must comply with the Cosmetic Labeling Management Measures (effective May 1, 2022, with a transition period ending May 1, 2024, now fully enforced) and the Regulations on the Supervision and Administration of Cosmetics (2021). As of 2026, customs and market supervision authorities are strictly enforcing these requirements, and non‑compliant labels are a leading cause of shipment holds and product delisting. Understanding the updated Chinese cosmetic labeling requirements for imported brands is essential to avoid costly delays and ensure smooth market access. This guide details all mandatory elements, common mistakes, and practical compliance strategies.
1. Mandatory Chinese Label – Format and Content
Since May 1, 2022, all imported cosmetics (including samples and gifts) must bear a Chinese label directly on the sales package or on an affixed sticker that is permanent and not easily removable. Key mandatory elements include:
- Product name – Must be in standard Chinese characters, not a direct translation that distorts meaning. Generic names (e.g., “whitening cream”) must be accurate.
- Registered/filed product name – The exact name approved by NMPA during registration or filing.
- Manufacturer‘s name and address – The overseas manufacturer‘s name and address as registered with NMPA.
- Importer/distributor name and address – The Chinese responsible party (local entity) responsible for compliance.
- Registration/filing certificate number – e.g., “Guo Zhuang Wang Jin 2025XXXX” or “Guo Zhuang Bei Zi 2025XXXX”.
- Full ingredient list – All ingredients must be listed in descending order by concentration, using standard INCI names or Chinese common names (see Section 3).
- Net content (fill volume or weight) – In metric units (g, mL).
- Production date and shelf‑life expiry date – Must be clearly marked, using year‑month‑day format.
- Instructions for use – If required for safe use.
- Precautions and warnings – Mandatory for specific product types (e.g., sunscreens, hair dyes, products for children under 3).
- Child safety warning – For products intended for children: “Please use under adult supervision.”
- Electronic label (optional) – QR code linking to additional information, but cannot replace mandatory physical label content.
2. Ingredient Labeling – INCI Names and Concentration Order
Ingredient labeling is a frequent source of rejection. Under the Cosmetic Labeling Management Measures:
- All ingredients must be listed using standard Chinese names corresponding to the Inventory of Existing Cosmetic Ingredients (IECIC) or approved new ingredient names. Trade names or brand names are not allowed.
- The order must be descending by weight/concentration at the time of manufacturing. Ingredients present at less than 1% may be listed in any order after those above 1%.
- Fragrance and flavor components can be labeled as “Fragrance” or “Flavor” unless they belong to the 26 declared allergenic fragrance substances (in which case individual labeling is required for consumer protection).
- Colorants must be declared using their standard index names (e.g., “CI 77492” for iron oxide yellow).
- For imported products, the INCI names on the original package must be matched to the IECIC standardized names. Discrepancies between foreign labels and Chinese labels (e.g., using a botanical extract name that differs from IECIC) cause rejection.
How to avoid: Before printing labels, cross‑reference every ingredient with the NMPA‘s IECIC database. Use the standardized name exactly as it appears in IECIC (pay attention to the 2025-2026 name updates). For new ingredients not yet in IECIC, ensure they have been properly filed and are within the safety monitoring period; label them as “New cosmetic ingredient” with the filing number.
3. Production Date and Expiry Date Labeling – Strict Format
Under the Cosmetic Labeling Management Measures, cosmetics must clearly indicate both the production date and the shelf‑life expiry date (no longer just “shelf life” in months). Key rules:
- The date format must be year‑month‑day, e.g., “20261201” or “2026年12月01日”. Other formats (e.g., “12/2026”) are not accepted.
- The expiry date must be marked after the phrase “Use before date” or “Expiry date”.
- For products with a shelf life of 30 months or more, the expiry date may be marked as “XX year XX month” (day may be omitted).
- The production date and expiry date must be printed directly on the packaging or on a permanent sticker that cannot be removed without damage. Avoid using inkjet printing that can be easily rubbed off.
Common mistake: Using Julian dates or codes that require a separate decoder ring. The expiry date must be directly readable by consumers. Any coded format is prohibited.
4. Warnings and Precautions – Product‑Specific Mandates
The following product categories have additional warning requirements:
- Products for children under 3 years – Must state: “Please use under adult supervision.”
- Hair dyes and oxidative products – Must include warnings about allergic reactions and a patch test recommendation.
- Sunscreens with SPF labeling – Must state the SPF value and PA rating (for UVA protection), and include warnings about reapplication.
- Aerosol products – Must have standard warnings: “Keep away from heat/flame. Do not puncture or incinerate.”
- Products containing alpha‑hydroxy acids (AHAs) – Must state: “Contains alpha‑hydroxy acids. Increases skin sensitivity to sun.”
- Whitening products – Must not claim any therapeutic effects; only NMPA‑approved whitening function claims are allowed, with the approval number referenced.
All warnings must be in simplified Chinese, clearly visible, and in a font size no smaller than the surrounding text.
5. Efficacy Claims – Evidence Required, Exaggeration Prohibited
Under the 2021 Cosmetic Regulations, any functional claim (e.g., “whitening”, “anti‑aging”, “moisturizing”) must be supported by efficacy evaluation evidence. For imported cosmetics, the evidence must be submitted during registration/filing. The label must not make claims that are not supported by the approved dossier. Common violations include:
- Claiming “organic” or “natural” without certification (China does not have a legal definition for “organic cosmetics”; such claims may be rejected).
- Claiming “hypoallergenic” or “dermatologist tested” without evidence; these claims are often considered misleading.
- Claiming medical or therapeutic effects (e.g., “treats acne”, “repairs damaged skin barrier”). Only NMPA‑approved whitening and sunscreen claims are allowed.
How to avoid: Only use claims that were approved during NMPA filing/registration. Retain efficacy test reports (human trials, in vitro tests, or literature review) for at least 3 years after the product ceases to be marketed.
6. Child Health Statement and Other General Notices
Though primarily for food, cosmetics intended for children or general use may be subject to general safety statements. Under China‘s Consumer Protection Law, the label must not contain any content that may mislead consumers about safety. While there is no universal “child health statement” for all cosmetics, products marketed with child‑friendly images should include “Not suitable for children under 3 years” where applicable.
7. Label Verification and Compliance Checklist
Before shipping products to China, use this checklist to verify your Chinese label:
- [ ] Chinese label physically affixed or printed on the package.
- [ ] Product name matches the NMPA registration/filing approval.
- [ ] Registration/filing certificate number correctly displayed.
- [ ] Importer’s name and address (China responsible party) clearly stated.
- [ ] Full ingredient list in descending order, using IECIC standardized names.
- [ ] Production date and expiry date in yyyy-mm-dd format.
- [ ] Net content in metric units.
- [ ] Required warnings present (child supervision, allergens, product‑specific).
- [ ] Efficacy claims match approved dossier.
- [ ] No prohibited claims (e.g., “organic”, “therapeutic”).
- [ ] Font size legible (minimum 1.8 mm for main text, 1.5 mm for warnings).
- [ ] Language: simplified Chinese only (or bilingual with Chinese equally prominent).
Summary: Updated Chinese cosmetic labeling requirements for imported brands mandate a Chinese label with full ingredient INCI names, production and expiry dates, registration numbers, warnings, and efficacy claims consistent with NMPA approval. Common mistakes include incorrect date formats, missing child warnings, mismatched ingredient names, and unsupported claims. By following the compliance checklist and engaging a local regulatory agent, importers can avoid customs holds and bring their products to market with confidence.