ZMUni Compliance Centre

On October 20, 2025, China's National Medical Products Administration (NMPA) announced a three-year pilot initiative for electronic cosmetic labels, marking a major step in the digitalization of cosmetic labeling in China. As one of the designated pilot regions, Shanghai officially launched the initiative on February 1, 2026.

As the implementation of the electronic cosmetic label initiative progresses, Shanghai Customs and Shanghai Medical Products Administration jointly issued an announcement on May 9, 2026 regarding the pilot application of electronic labels for imported cosmetics in Shanghai. The measures are intended to further optimize the port business environment and support the adoption of digital labeling practices for imported cosmetics.

The first phase of the pilot will be carried out in Shanghai's Pudong New Area. Participating companies must be registered in Pudong New Area, and eligible products must be imported through ports located within the district. The measures officially took effect on May 11, 2026.

Products included in the pilot are limited to imports under general trade or other designated import/export modes. Declarations must be submitted through the China (Shanghai) International Trade "Single Window" system to designated customs offices. Companies are required to indicate "electronic label pilot" in the "Inspection and Quarantine Goods Specifications" field of the customs declaration form, and "G + item number + electronic label pilot" in the remarks section. Customs authorities will automatically compare the declaration information with electronic data provided by the drug regulatory authority.

Under the pilot framework, the municipal drug administration authority will be responsible for transmitting pilot-related data, while district-level market supervision authorities will oversee routine supervision and inspection activities. Shanghai Customs will verify whether key information displayed on product packaging - including the Chinese product name, registration certificate number, net content, expiration date, and children's cosmetics logo - is consistent with the declaration information. Customs will also confirm that the name of the registrant or notifier, as well as relevant safety warning statements, are properly labeled.

In addition, Shanghai Customs clarified that it will no longer separately verify QR code information associated with electronic labels for pilot products, further streamlining customs clearance procedures for participating companies.