For companies developing or exporting sunscreen products to China, these changes reinforce the importance of robust product testing, accurate efficacy claims and careful regulatory planning before entering the market.
Greater emphasis on sunscreen efficacy and quality
The new NIFDC technical guidelines provide additional direction on the research, development and quality control of sunscreen cosmetics. They are intended to improve consistency in product evaluation and ensure that manufacturers generate reliable scientific evidence to support product performance.
Particular attention is given to demonstrating the effectiveness of sunscreen products through validated testing methods. Manufacturers are expected to substantiate claims such as Sun Protection Factor (SPF), UVA protection and water resistance using the methodologies recognised by the Chinese authorities.
An important practical consequence is that sunscreen claims displayed on products sold in China must be supported by test results obtained according to Chinese regulatory standards. If imported products carry SPF, PA or water-resistance claims that differ from results generated using China’s official test methods, manufacturers may need to adapt packaging specifically for the Chinese market.
Updated safety testing is now mandatory
Alongside the technical guidance, China has implemented new toxicological testing requirements under NMPA Announcement No. 5 of 2026. After a transition period, these revised methods became mandatory for cosmetic registration and filing from 1 July 2026.
The update introduces new approaches for skin sensitisation assessment and toxicokinetic evaluation while also revising existing human safety testing and skin patch testing methods. Together, these changes are designed to provide more comprehensive information on ingredient safety and systemic exposure.
Although the requirements apply across cosmetic categories, sunscreen formulations often require particularly careful evaluation because they contain active UV filters and frequently make performance-related claims.
What manufacturers should consider
Companies planning to place sunscreen cosmetics on the Chinese market should review both their technical documentation and product development processes. Compliance increasingly depends not only on selecting permitted UV filters, but also on producing high-quality scientific data that supports product safety, efficacy and labelling.
Manufacturers should also ensure that testing is carried out using methods accepted by the Chinese authorities and verify that product claims remain consistent with the evidence submitted during registration or filing. Early planning can help avoid delays caused by additional testing or dossier revisions.
A continuing evolution of China’s cosmetic regulations
The latest sunscreen guidance reflects a broader trend within China’s cosmetic regulatory system. Since the introduction of the Cosmetics Supervision and Administration Regulation (CSAR), authorities have progressively expanded technical requirements, strengthened scientific evaluation and increased expectations for supporting documentation.
Rather than introducing isolated changes, the recent measures form part of a wider strategy aimed at improving product safety, standardising testing procedures and ensuring that cosmetic claims are backed by reliable evidence. Companies intending to access the Chinese cosmetics market should therefore expect regulatory requirements to continue evolving and incorporate ongoing regulatory monitoring into their compliance strategies.
