Last month, ZMUni Compliance Centre hosted a webinar focused on compliance requirements for special cosmetics in China. During the session, we introduced the basic definitions, regulatory pathways including registration n timelines for different product types, and shared typical enforcement cases involving non-compliant formulations.
One major concern was the potential criminal liability linked to the use of prohibited or unapproved cosmetic ingredients — a growing issue in recent years. These cases highlight the need for full compliance, not just in formulation, but also in labeling and documentation.
To manage these risks, companies must understand China's regulatory ingredient references. The Safety and Technical Standards for Cosmetics (STSC 2015) includes two main sections:
Chapter 2 outlines prohibited and restricted substances across three tables: prohibited substabces (Table I), prohibited plant/animal-derived substances (Table II), and restricted substances (Table III).
Chapter 3 lists permitted substances, including preservatives (Table IV), sunscreen agents (Table V), colorants (Table VI), and hair dye agents(Table VII).
Additionally, the Inventory of Existing Cosmetic Ingredients in China (IECIC 2021) serves as a dynamic reference. However, ingredients in this list may be reclassified as restricted or prohibited based on updated safety data.
Given this regulatory context, this article aims to provide overseas enterprises with a clear overview of the permitted sustances for special cosmetics in China, along with relevant usage conditions. Based on product classification,ingredients used in special cosmetics in China generally fall into five key categories: sunscreen agents, hair dye agents, perming agents, anti-hair loss agents, and whitening or spot-removing agents.
Safety and Technical Standards for Cosmetics (STSC 2015) provides clear and detailed requirements for the use of sunscreen agents and hair dye agents in cosmetics. Specifically, Table V - List of Permitted Sunscreen Agents in Cosmetic Products lists 27 approved sunscreen agents permitted for use in cosmetic products in China.
It is worth noting that in May 2021, China's National Medical Products Administration (NMPA) updated the List of Prohibited Substance in Cosmetic Products, and 3-Benzylidene Camphor—previously listed as a permitted ingredient in Table V—was officially reclassified as a prohibited substance. So, currently there are 26 approved sunscreen agents in China.
*Note for global brands: Any formula containing 3-Benzylidene Camphor now is strictly banned from production, import, or sale in China.
*List of Permitted Sunscreen Agents in Cosmetic Products in China
The STSC 2015 lists 75 permitted hair dye agents. However, in 2021, China NMPA included 2-Chloro-p-phenylenediamine and 2-Chloro-p-phenylenediamine sulfate, previously listed as permitted substances in Table VII—was officially reclassified as prohibited substances. So, currently there are 73 approved hair dye agents in China.
*List of Permitted Hair Dye Agents in Cosmetic Products in China
Currently, STSC 2015 do not provide a separate List of Permitted Hair Perming Agents. However, relevant substances are specified in the List of Restricted Ingredients in Cosmetic Products within the STSC 2015.
Details are shown in the table below:
*Hair perming agents as specified in the List of Restricted Substance in the STSC 2015 in China
According to the currently published registration certificates for anti-hair loss products, the approved active ingredients used in such products are as follows:
*Approved Anti-Hair Loss Agents in China
Currently, China has not issued an official list of permitted whitening or freckle-removing substance. However, guidance is available in the draft document:
Technical Guidelines for Special Cosmetics with Freckle-Removing and Whitening Functions (Draft for Comments), which outlines three pathways for ingredient justification:
1. Use of registered new cosmetic ingredients with documented whitening efficacy — the ingredient must meet its approved usage purpose, dosage, scope, and safety conditions.
2. Reference to global regulatory approvals — for example, ingredients approved as whitening agents in regions with similar skin types (e.g., South Korea, Taiwan, China) may be supported by regulatory documents.
3. In-house efficacy research and safety validation — through mechanistic studies and formulation-based evaluations.
*Whitening Agents Approved in South Korea
*Whitening Agents Approved in Taiwan, China
Additionally, the NMPA released the "Rational Understanding and Use of Whitening Cosmetics" in 2020, listing commonly used active ingredients for whitening functions.
*Commonly Used Whitening Ingredients in China
In August 2023, two inspection methods were also issued by China NMPA for a total of 13 ingredients with a history of whitening use in China, details as follows:
*13 Whitening Ingredients Listed in IECIC with Testing Methods
While China has not yet published a complete master list for all permitted ingredients in special cosmetics, companies can refer to the existing technical standards, regulatory announcements, and guidelines to make informed R&D and compliance decisions.
As regulatory policies continue to evolve and technical requirements become more precise, China is expected to release clearer and more systematic ingredient catalogue—enabling cosmetic companies to navigate the special cosmetics sector with greater confidence and compliance.
Also, if you would like to obtain the PDF versions of the referenced documents, please contact us via info@zmuni.com.
*Disclaimer: The ingredient information provided above has been compiled and summarized by ZMUni Compliance Centre based on official sources. For the most accurate and up-to-date details, please refer to the official government publications.
