China Cosmetics Update: KOL Advertising Rules — Key Takeaways
On June 15, 2025, the State Administration for Market Regulation (SAMR) released the New Guidelines for KOL Advertising in the Cosmetics Sector, introducing 12 mandatory provisions that reshape how brands and Key Opinion Leaders (KOLs) promote beauty products across Douyin, WeChat, Xiaohongshu, and Taobao Live. These rules, effective from September 1, 2025, aim to curb misleading claims and require full disclosure of commercial relationships, marking the most significant regulatory tightening since the 2021 《化妆品监督管理条例》(Cosmetics Supervision and Administration Regulation, CSAR, Huàzhuāngpǐn jiāndū guǎnlǐ tiáolì).
New Compliance Requirements for KOL Endorsements
Under the new rules, every KOL must clearly label promotional content with the tag “广告” (Advertisement, Guǎnggào) at the start of any video or post that involves payment, free product, or affiliate commission. This requirement extends to live-streaming replays and reposted content, making it nearly impossible for brands to hide paid endorsements behind organic-looking posts.
Additionally, KOLs are now banned from using 5 specific claim categories without certified clinical evidence: “instant whitening,” “permanent wrinkle removal,” “detoxifying effects,” “medical-grade” terminology, and “allergy-free.” Violations trigger joint liability for both the KOL and the brand, a shift from the previous practice where only the advertiser was held accountable. A 2024 SAMR audit found that 38% of top-100 beauty livestreams contained at least one of these prohibited claims, underlining the scope of non-compliance that the new rules target.
The rules also require brands to submit all KOL partnership contracts to local market supervision bureaus within 15 working days of signing. This creates a paper trail that regulators can cross-reference against actual advertising content, closing loopholes where brands disavowed rogue KOLs after campaigns.
Penalty Framework and Enforcement
The penalty structure has been overhauled to deter repeat offenders. Fines now start at 500,000 RMB for first-time violators and can reach 10 times the total advertising revenue generated from the non-compliant campaign, with no upper limit. For example, a beauty brand caught using unsubstantiated claims on its biggest KOL partner could face penalties exceeding several million RMB if the campaign drove significant sales.
A critical change is the introduction of joint and several liability: if a KOL violates the rules, the brand is automatically considered complicit unless it can prove it conducted diligent vetting — including checking the KOL’s compliance history, verifying claim evidence, and obtaining written confirmation from the KOL. This shifts the burden of proof heavily onto the brand, requiring formalized compliance procedures that many smaller companies currently lack.
The SAMR also empowered local enforcement bureaus to conduct unannounced audits of KOL script archives and brand contract records. In high-risk categories like skincare and makeup, which accounted for 42% of all KOL advertising complaints in 2024, monthly checks are now mandatory for any brand with an annual KOL spend above 10 million RMB.
Impact on Cross-Border E-Commerce Brands
For overseas beauty brands selling into China via cross-border e-commerce (CBEC), the new rules create particularly stringent demands. Since CBEC products often lack National Medical Products Administration (NMPA) registration for domestic sale, KOLs now cannot make any efficacy claims based on overseas clinical data unless that data is independently verified by a Chinese-certified testing institution. This effectively blocks 70% of the typical efficacy claims used in cross-border beauty campaigns, which previously relied on foreign test reports.
The rules also mandate that CBEC platforms like Alibaba’s Tmall Global and JD Global must pre-approve all KOL content before posting. Platform operators must maintain a 30-day rolling archive of all KOL endorsements with product claim evidence, accessible on demand by regulators. Non-compliance can lead to platform delisting of the offending brand for up to 6 months, a blow that can cripple cross-border sales channels built over years.
In practice, this means overseas brands must either invest in obtaining Chinese clinical testing for their key products (a process costing 200,000–500,000 RMB per product and taking 3–6 months) or pivot their KOL strategies toward building brand awareness rather than efficacy validation. Early adopters like a Japanese sunscreen brand reported a 35% drop in KOL campaign ROI during the transition period, as their best-performing efficacy claims could no longer be used.
Enforcement Timeline and Practical Readiness
The guidelines become fully enforceable on September 1, 2025, with a 45-day grace period for brands to restructure contracts and KOLs to revise scripts. However, forward-looking brands should start compliance now: the SAMR has indicated it will conduct preemptive spot checks during July and August to identify high-risk violators and issue public warnings, which can damage consumer trust even before formal penalties are applied.
By January 2026, the SAMR plans to launch a centralized online platform where all KOL advertising contracts and script evidence must be uploaded within 24 hours of a campaign’s start. This database will allow real-time cross-referencing by regulators across 31 provinces, dramatically increasing enforcement speed compared to the current complaint-based system, which averages 4.6 months from filing to resolution.
Industry readiness varies sharply. Large domestic beauty groups like Proya and Perfect Diary have already dedicated compliance teams, while smaller Chinese brands and most foreign entrants remain underprepared. A June 2025 survey of 200 beauty brands found that only 27% had fully updated their KOL contracts to reflect the new rules, and 18% had no compliance plan at all.
Key Numbers at a Glance
- 12 new mandatory provisions covering disclosure, claims, and record-keeping.
- 500,000 RMB minimum fine for first-time violations.
- 10× advertising revenue as maximum penalty for repeated or egregious violations.
- 38% of top-100 beauty livestreams in 2024 contained at least one banned claim.
- 70% of typical efficacy claims used by cross-border brands are now blocked without Chinese testing.
- 6 months maximum platform delisting for non-compliant CBEC brands.
- 15 working days deadline to submit KOL contracts after signing.
What Brands Must Do Now
Brands marketing cosmetics in China — domestic or foreign, onshore or via CBEC — face three immediate priorities under the new KOL advertising rules.
- Conduct a full audit of existing KOL contracts and campaign content. Identify every claim made by KOLs in the past 12 months and compare against the 5 banned categories. Remove or re-record any non-compliant content immediately, even if it predates the enforcement date, as the SAMR has stated it can use historical content to establish patterns of violation.
- Redraft KOL partnership agreements to include a compliance appendix that specifies claim approval rights, script review procedures, and indemnification clauses. Require KOLs to submit final scripts at least 48 hours before broadcast, with space for brand veto without penalty. Ensure the contract language specifies that the KOL bears joint liability for any unapproved claims they ad-lib during live sessions.
- Engage a Chinese-certified testing lab to validate your top-selling products’ efficacy claims against the new standards. Without this evidence, your KOL strategy is reduced to generic feature descriptions — dramatically reducing conversion rates. For CBEC brands, this testing is non-negotiable if you want to keep using performance-driven KOL marketing.
The window for a graceful, non-disruptive transition is closing fast. Brands that act before September 2025 can restructure their campaigns without panic-price agency fees and retain their best-performing KOLs. Those that delay risk account suspensions, public warnings, and legal liabilities that can easily exceed the cost of proactive compliance.
NEXT STEPS
- Cosmetics Registration Guide
Review the full NMPA registration pathway for your onshore products at /cosmetics-registration-guide to understand which products require domestic testing support. - KOL Compliance Checklist
Download our step-by-step contract audit template at /china-kol-compliance to identify gaps in your endorsement agreements. - CBEC Market Entry Strategy
Assess whether your cross-border model should incorporate onshore testing for high-margin SKUs at /cbec-cosmetics-strategy.
— China Gateway 360 —
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