When toxicology testing is required, and when it may be waived

Toxicology testing is neither always mandatory nor always optional. The Provisions on Management of Cosmetics Registration and Filing Dossiers allow an ordinary cosmetic to omit a toxicology test report when the manufacturer has a quality-management certificate issued by the government authority of its country or region and the safety assessment can fully confirm the product’s safety. That waiver does not apply to products claimed for infants or children, products that use a new ingredient still under safety monitoring, or cases where the filer, Domestic Responsible Person or manufacturer has been listed as a priority supervision target. If several manufacturers are involved, they generally all need the relevant certificates before the waiver applies.

Published 11 November 2026 · Updated 11 November 2026

How Announcement No. 70 of 2026 changed the picture

The 2026 announcement extends a similar waiver, under the same two conditions, to perm products, non-oxidative hair dyes, whitening or spot-removal products that work only by physical covering, and ordinary cosmetics that use a new ingredient (other than children’s cosmetics). The announcement also states that technical reviewers may adjust the waiver scope later through guidance. Decide each product against the current text rather than by analogy. Sunscreen, oxidative hair dyes and anti-hair-loss products are not described in that extended list.

When testing should still be arranged

If safety cannot be fully confirmed by assessment, if the company does not hold the required certificates, or if the product sits outside the waiver, arrange toxicology at a qualified inspection institution. Children’s cosmetics should generally submit the corresponding toxicology materials. Special cosmetics often include safety tests that match the product type under the Safety and Technical Standards for Cosmetics and the inspection rules.

Cautions

A waived toxicology report does not waive the safety assessment. Whether animal-testing alternatives may be used is a separate question and follows the methods recognized at the time. We do not promise a waiver for every imported product.

Questions we are often asked

Can we skip toxicology if we already have EU animal-testing-free tests?

Only if the Chinese waiver conditions are met or a recognized alternative method satisfies the current Chinese inspection rules. An overseas report is not automatically a waiver.

Do all manufacturers in a multi-site file need certificates?

Generally yes, when the waiver depends on quality-system certificates. If any site lacks the certificate, do not assume the waiver applies to the whole product.