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Guide
Complete vs simplified cosmetic safety assessment
It is no longer useful to treat “complete versus simplified” as a free choice. NMPA Announcement No. 50 of 2024 created classified management of safety-assessment materials. Until 1 May 2025, registrants or filers could still submit a simplified report that met the Technical Guidelines for Cosmetic Safety Assessment (2021). After that transition, new registrations and filings should follow the current submission guide: special cosmetics, infant and children’s cosmetics, and cosmetics that use a new ingredient still under safety monitoring should submit a safety-assessment report; certain other ordinary cosmetics may submit a basic conclusion if their quality-management system is running well, while keeping the full report on file for inspection.
How to judge which file to submit
According to the National Institutes for Food and Drug Control submission guide, the first category—special cosmetics, infant and children’s cosmetics, and products using a monitored new ingredient—submits a safety-assessment report. Higher-risk situations among other products, such as the use of nano ingredients, certain efficacy claims, sheet masks or aerosols, or products that must be used with a device, may need extra assessment materials besides a basic conclusion. Remaining ordinary cosmetics may submit the basic conclusion and keep the full report on file. A company may always submit a full report.
What a full report usually contains
A complete assessment typically covers each formula ingredient, substances of concern, product stability, compatibility with packaging, and preservative challenge, together with conclusions and assessor information. Evidence types that the simplified report once allowed, such as the highest historical use level published by regulators, are not used in the same way in a complete report. Follow the 2021 guidelines and the current submission guide for the exact chapters.
Cautions
In 2026, decide the category first instead of asking whether a simplified report is “still acceptable.” Stored reports must remain available for inspection and must match the formula and method of use. Children’s cosmetics and special cosmetics should not be forced onto the basic-conclusion route used by some adult ordinary cosmetics.
Questions we are often asked
Is a simplified report still accepted for a new 2026 filing?
The transition that still allowed 2021-style simplified reports ran until 1 May 2025. New filings and registrations should follow the classified submission rules now in force.
Can an MSDS replace the safety-assessment report?
No. They answer different questions and follow different standards.
Next step
Discuss your China market path
Tell us whether you plan to import finished goods or manufacture in mainland China, and what the product claims. We will outline the likely filing or registration path. Testing, where needed, is arranged with partner laboratories.
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