ZMUni Compliance Centre

On October 20, 2025, China's National Medical Products Administration (NMPA) announced a three-year pilot program for electronic cosmetic labels, marking a significant step toward the digital transformation of cosmetic labeling in China. The pilot will begin on February 1, 2026, and will be implemented in Beijing, Shanghai, Zhejiang, Shandong, Guangdong, and Chongqing. The duty-free cosmetics pilot on Hainan Island, launched locally in September 2024, may also be carried out under the new NMPA requirements.

The pilot aims to optimize labeling management, enhance consumer access to product information, address the needs of elderly users, and facilitate business operations, supporting the high-quality development of China's cosmetics industry.

Under this program, cosmetics (including toothpaste) can display their Chinese labeling information through electronic means, using a QR code generated via an authorized information system. Consumers can scan the code using commonly used communication or payment apps to instantly access verified product information. Electronic labels are considered an official part of the cosmetics labeling, and must comply with the Cosmetic Supervision and Administration Regulation (CSAR) as well as supporting regulations and technical documents in China.

Provincial medical products administrations participating in the pilot must define local regulatory requirements and supervision measures, select and confirm pilot enterprises, and publish the enterprise lists on their official websites. They are responsible for advance the pilot steadily and address key challenges promptly, and establishing a standardized and efficient management model for the application of electronic cosmetic labels. 

The pilot program must comply with the Working Requirements for the Pilot Program of Electronic Cosmetic Labels, and enterprises are required to develop their electronic labeling systems in accordance with the Electronic Cosmetic Label Data Set and the Technical Specification for QR Codes of Electronic Cosmetic Labels issued alongside the Notice.