Cosmetic labels sold in China must comply with GB 5296.3-2008 (消费品使用说明 化妆品通用标签, xiāofèipǐn shǐyòng shuōmíng huàzhuāngpǐn tōngyòng biāoqiān) and NMPA’s Cosmetics Labeling Management Measures (化妆品标签管理办法) effective May 1, 2022, which together require Chinese-language labels listing at least 14 mandatory elements including product name, ingredient list in IECIC-standard Chinese names, net content, date of manufacture or production batch, shelf life, NMPA registration or notification number, and the full address of the responsible party in China.
Legal Framework for Cosmetic Labeling in China
China’s cosmetic labeling regulations are governed by a layered framework of national standards, administrative measures, and NMPA guidance documents. The key instruments are:
- GB 5296.3-2008 — General rules for labeling of consumer products: cosmetics (化妆品通用标签). Establishes the baseline labeling requirements applicable to all cosmetic products sold in China. Despite being published in 2008, it remains the current national standard, supplemented by the newer Labeling Management Measures.
- Cosmetics Labeling Management Measures (化妆品标签管理办法) — Issued by NMPA and effective May 1, 2022, replacing several earlier circulars. This is the primary regulatory document for label content, format, and language requirements. Non-compliance can result in fines of RMB 10,000–30,000 and product seizure.
- GB 38598-2020 — General requirements for cosmetic packaging (化妆品包装通用要求). Governs packaging materials, child-resistant closures, and environmental labeling for cosmetics.
- Advertising Law (广告法) — Prohibits false or misleading claims on packaging, including unsubstantiated efficacy statements.
Foreign brands must appoint a responsible person in China (境内责任人, jìng nèi zérèn rén) — typically the entity that holds the NMPA registration or notification — whose name and address must appear on the label. This is a non-negotiable requirement under the Cosmetics Labeling Management Measures Article 6.
Mandatory Label Elements: Complete Checklist
Every cosmetic product sold in China must display the following 14 elements on its label. The first test of any new label is whether all 14 are present:
| # | Label Element | Regulatory Basis | Notes for Foreign Brands |
|---|---|---|---|
| 1 | Product name (产品名称) | Labeling Measures Art. 7 | Must include both Chinese name and original foreign name. Standardized format: registered trademark + common name + attribute name |
| 2 | Responsible party name and address (境内责任人名称和地址) | Labeling Measures Art. 6 | Must be a legal entity registered in China |
| 3 | Actual manufacturer name and address (生产企业名称和地址) | Labeling Measures Art. 8 | For imported products, include the overseas manufacturer’s name and address |
| 4 | NMPA registration or notification number (注册证编号或备案编号) | Labeling Measures Art. 9 | Format: “国妆特字GXXXXXXXX” for special cosmetics; “国妆网备进字XXXXXXXX” for imported general cosmetics |
| 5 | Full ingredient list (全成分表) | GB 5296.3 Art. 6.4 | Descending order of concentration; use IECIC Chinese standard names |
| 6 | Net content (净含量) | Labeling Measures Art. 10 | SI units (g, mL) mandatory |
| 7 | Date of manufacture or production batch (生产批号) | Labeling Measures Art. 11 | One of: manufacture date, production batch code, or both |
| 8 | Shelf life / Expiration date (保质期/限期使用日期) | Labeling Measures Art. 12 | Format: “限期使用日期：YYYY/MM/DD” or “保质期：XX个月” |
| 9 | Instructions for use (使用方法) | GB 5296.3 Art. 6.6 | For products requiring specific application instructions (e.g., sunscreens, hair dyes) |
| 10 | Precautions and warnings (注意事项) | Labeling Measures Art. 13 | Warning statements for restricted ingredients, allergens, or special product types |
| 11 | Storage conditions (贮存条件) | GB 5296.3 Art. 6.8 | Required if special storage is needed |
| 12 | Country of origin (原产国) | Labeling Measures Art. 14 | For imported products only |
| 13 | Product classification code and type (产品类别) | Labeling Measures Art. 15 | General vs. special cosmetics classification must match NMPA registration |
| 14 | Post-sales service contact information (售后服务机构信息) | Labeling Measures Art. 16 | Chinese-language telephone number or online customer service channel |
All text must be in Chinese (simplified characters). Foreign languages may appear alongside the Chinese text but must not exceed the font size of the Chinese characters. Bilingual labels should place Chinese first or equally prominently.
Ingredient Labeling Rules: What Goes on the List
The ingredient list (全成分表) is one of the most technically demanding aspects of cosmetic labeling compliance. Strict rules govern what goes on the list and how ingredients are named:
Descending concentration order. Ingredients must be listed in descending order of concentration at the time of product manufacture. This means the ingredient with the highest percentage appears first. Water (水, shuǐ) is typically listed first for most products. Trace ingredients (concentration below 0.1% in leave-on products, below 0.01% in rinse-off products) may be listed in any order after the descending-order portion.
IECIC Chinese standard names only. Every ingredient must be listed using its Chinese standard name (中文标准名称) from the IECIC (已使用化妆品原料目录). Using an unapproved translation or the INCI name alone is a common violation that can delay customs clearance. For example, “hyaluronic acid” must be listed as “透明质酸” (tòumíngzhì suān), and “niacinamide” as “烟酰胺” (yānxiān’àn). The NMPA publishes a cross-reference table mapping INCI names to Chinese standard names.
Fragrance and flavor. Fragrance (香精, xiāngjīng) may be listed as a single entry, but specific allergens required to be declared under EU regulations are not separately required in China unless they serve a functional purpose beyond scent. However, the NMPA’s 2025 guidance recommended voluntary declaration of common allergens.
Nanomaterials. Ingredients in nanoparticle form must be noted with “(纳米级)” (nàmǐ jí) after the ingredient name. This is required under GB 38598-2020 Article 5.3.
Special Label Requirements by Product Category
Different cosmetic product categories have additional labeling requirements beyond the 14 mandatory elements:
Special cosmetics (特殊化妆品, tèshū huàzhuāngpǐn) — Including sunscreens (防晒, fángshài), whitening (美白, měibái), hair dyes (染发, rǎnfà), and perms (烫发, tàngfà). These products must display the approved NMPA claim wording verbatim on the label. No deviation from the registered wording is permitted. The SPF and PA ratings on label must exactly match the NMPA registration certificate.
Children’s cosmetics (儿童化妆品, értóng huàzhuāngpǐn) — Subject to GB/T 37545-2019 and the NMPA’s 2021 notice on children’s cosmetics, these labels require: the “小金盾” (xiǎo jīndùn, golden shield) logo introduced in 2022, the statement “适用于儿童” (shìyòng yú értóng, suitable for children), explicit age range (e.g., “3岁以上” for ages 3+), and a stronger warnings section listing potential allergic reactions.
Imported cosmetics (进口化妆品, jìnkǒu huàzhuāngpǐn) — Must bear a Chinese-language sticker label (中文标签, zhōngwén biāoqiān) affixed to the original packaging before sale in China. The sticker must not obscure the original label information. Imported products subject to animal testing (still required for some special cosmetics) must carry a corresponding statement if the NMPA mandates it. The country of origin (原产国, yuánchǎn guó) must be clearly stated.
Common Labeling Violations and How to Avoid Them
The NMPA’s 2025 cosmetic label inspection campaign reviewed over 15,000 products and found a non-compliance rate of approximately 18%. The most common violations were:
- Missing Chinese-language sticker (23% of violations) — Imported products being sold online or in retail without a Chinese-language label affixed. Fine: RMB 10,000–30,000 per SKU. Fix: Establish a label-sticker workflow before products reach the NMPA-designated responsible person’s warehouse in China.
- Incorrect NMPA registration/notification number (18% of violations) — The label displays the incorrect number format, an expired number, or the number is missing entirely. Fix: Include the NMPA number on the pre-print label at the point of manufacture. For imported products with sticker labels, double-check the number against the NMPA database (www.nmpa.gov.cn).
- Non-IECIC ingredient names (15% of violations) — Using INCI English names without the Chinese standard name, or using an unapproved translation. Fix: Engage a regulatory consultant to review the ingredient list against the IECIC before label printing.
- Efficacy claims inconsistent with registration (14% of violations) — The label claims a function (e.g., “SPF 50+”) that does not match the NMPA-registered claim (e.g., “SPF 30”). Fix: Pre-approve all label claims against the NMPA registration certificate before production.
- Responsible party information missing or outdated (12% of violations) — The responsible party’s name or address on the label does not match the entity registered with the NMPA. Fix: Conduct a quarterly label audit comparing label information against current NMPA registration records.
Products found non-compliant during NMPA inspections may be ordered off shelves, and repeat violations can lead to suspension of the responsible party’s registration and notification privileges.
E-Labeling and the Digital Transition
In 2025, the NMPA began piloting electronic labeling (电子标签, diànzǐ biāoqiān) for certain cosmetic categories. Under the pilot program, products sold through designated e-commerce platforms (including Tmall Global and JD Worldwide) may use a QR code that links to the full Chinese-language label information hosted on NMPA’s cloud database. The QR code must be placed on the physical product packaging alongside a simplified sticker containing: product name, batch number, expiration date, and responsible party information.
The electronic labeling pilot (currently covering approximately 300 product SKUs across 50 participating brands) is expected to be expanded in 2027. Brands participating in the pilot report a 30–50% reduction in label printing costs and a 2–3 week reduction in time-to-shelf for new products, as label-content corrections can be updated in the database rather than requiring reprinting.
Where to Go From Here
Based on what you just read:
- Ready to act? Read [guide: SLUG-TO-BE-FILLED]
- Still comparing? See [comparison: SLUG-TO-BE-FILLED]
- Need numbers? Try [tool: SLUG-TO-BE-FILLED]
What labeling rules apply to cosmetics sold in China? — first published on China Gateway 360. Last updated: July 2026.
