Cosmetic ingredients for China run on a whitelist — and the old usage data expired in May 2025

Two things decide whether a cosmetic formula can be sold in China, and neither is about the finished product. The first is whether each ingredient is permitted at all. The second is whether the company can evidence that it is safe as used — and the evidence base for that second question changed on 1 May 2025, when historical maximum use levels from the 2021 inventory ceased to be an acceptable basis for a safety assessment.

Companies whose Chinese filings lean on ingredient codes rather than on real supplier data are the ones this affects, and many of them do not know it yet.

The whitelist, and the three lists inside it

Article 37 of 《化妆品监督管理条例》 — the Regulations on the Supervision and Administration of Cosmetics, State Council Order No. 727 — requires cosmetic ingredients, and packaging in direct contact with the cosmetic, to conform to mandatory national standards and technical specifications. 《化妆品安全技术规范（2015版）》 then divides ingredients into three lists:

• Prohibited — absolutely not permitted, without exception or threshold
• Restricted — permitted within stated conditions and limits
• Permitted — allowed for the stated purpose, covering colourants, preservatives, sunscreens and hair dyes

China operates these as a whitelist: what is not permitted is not usable. This is the opposite of the intuition a formulator brings from a market where anything not prohibited may be used. It is why a formula that is entirely lawful elsewhere can be unusable here without a single ingredient being unsafe.

New ingredients that pass a three-year monitoring period without a safety issue are added to the used-ingredient inventory, which is how the permitted set expands.

What a supplier file has to contain

Cosmetic ingredients are fine chemicals, and the documentary review is a chemical review. The source documentation is where it usually falls short, and the requirement varies by origin:

• Plant-derived — the geographic source, and whether the material is cultivated or wild-collected
• Animal-derived — a quarantine certificate for the animal-derived material
• Synthetic — the synthesis route and evidence of the starting materials
• Imported — the customs declaration, the inspection and quarantine certificate, and the authorisation documents for the domestic responsible party

Beyond the source file, assessment follows 《化妆品安全评估技术导则（2021年版）》 — the Technical Guidelines for Cosmetic Safety Assessment (2021 edition) — and the technical guidance and guidelines on submitting ingredient safety information.

The May 2025 change, and why it matters more than it sounds

Under the earlier arrangement, an ingredient code (the mechanism often referred to as attachment 14) could be obtained and matched against a name in the used-ingredient inventory, and the historical maximum use level recorded there could carry the safety assessment. Two weaknesses in that arrangement became apparent:

• Submission was never genuinely mandatory for ingredient suppliers, so a large share of the safety information behind those codes was thin or blank.
• Since 1 May 2025, the 2021-version historical maximum use levels can no longer serve as an assessment basis. Recommended addition levels bound to old codes have therefore lapsed, and where a supplier has not remediated, the brand owner inherits misleading data.

The regulatory direction of travel is away from the formal artefact and back to the substance: the registrant or filer is the first responsible party, expected to hold the documentation on file for inspection. Whether a particular submission form survives in its current shape is a secondary question. What does not change is that a brand must be able to show, from its own records, why each ingredient is safe as used.

The practical consequence for a company importing into China is that supplier auditing stops being a quality-system nicety and becomes the source of its regulatory position. That means the ordinary audit apparatus, applied to ingredient suppliers:

• Business licence, and production licence where applicable
• Quality management system certification, where held
• Periodic third-party type-test reports
• An annual audit record, on site or documentary

Where this meets the customs file

Ingredient compliance is decided long before a shipment, but it surfaces at the border in two ways. Imported ingredients need their own import documentation: declaration, inspection certificate, and the authorisation for the domestic responsible party. On entry, finished cosmetics are tested against the safety and technical standards, with heavy metals and microbiological limits among the routine items.

A formula that passes on paper and fails on test is usually a manufacturing or storage problem rather than a formulation one. The outcome at the port is the same either way: goods that may not be sold or used, and a destruction or re-export order.

A workable order of operations

Check each ingredient against the prohibited, restricted and permitted lists as they currently stand. Assemble the source documentation according to what kind of ingredient it is, rather than assuming a code stands in for it. Confirm that no part of the safety assessment still rests on historical maximum use levels. Then audit the suppliers who provided the data, because after May 2025 that is where the assessment actually comes from.

For a first import, this work sits before the filing, and the filing sits before the label — the filing number has to be printed on the package.