China updates cosmetics test methods: check the two implementation dates
How the seven methods enter the technical specification
The National Medical Products Administration has incorporated seven testing methods into the Technical Specification for the Safety of Cosmetics. Five revised methods replace existing methods, while two methods are new.
The summary table identifies revisions to the general microbiological testing method and the methods for aerobic plate count, thermotolerant coliform bacteria, Staphylococcus aureus, and mould and yeast count. The method for the Burkholderia cepacia complex and the collagen gel eye irritation test are additions. The methods do not all take effect on the same date.
Effective dates and practical impact
Six microbiological methods take effect on December 1, 2027. The collagen gel eye irritation test takes effect on May 1, 2027. Before those dates, the notice encourages use of the new methods in testing connected with cosmetics registration and filing.
Companies planning registration or filing tests, and the laboratories they engage, should check the testing schedule, commissioning requirements, and method version cited in each report against the applicable date.
Preparing for the method transition
Companies can ask their testing teams to compare the summary table with all seven method texts, identify applicable tests, review method suitability and quality controls, and update testing plans for the relevant implementation dates.
The general microbiological method also addresses sampling, method suitability, culture medium quality control, and records and reports. Laboratories should confirm the operational details for each sample and method. The notice does not state that every previously submitted application must provide replacement materials; reviewing a dossier is a practical recommendation, not a new official obligation.
Regulix can help cosmetics registration and filing teams check technical dossiers and testing references, including whether existing submission materials need updating for the applicable method. Testing procedures and results remain the responsibility of appropriately capable laboratories.
