Is There a "Chinese CosIng"? IECIC Compared With the EU's CosIng Inventory

Formulators searching "china cosing" or "cosing china" are usually looking for one thing: a Chinese equivalent of the EU's CosIng database, something they can check the way they check CosIng before exporting a formula. China does not have a CosIng. It has the Inventory of Existing Cosmetic Ingredients in China (IECIC), and the two systems work on different legal logic. Confusing them is an easy way to misjudge what a shipment to China actually requires.

What IECIC is and where it sits in Chinese law

IECIC is maintained by China's National Medical Products Administration (NMPA) under the Regulations on Supervision and Administration of Cosmetics (CSAR), the State Council regulation that has governed China's cosmetics sector since 2021. IECIC lists cosmetic ingredients that are already known to Chinese regulators, either because they were on the original 2021 inventory or because they have since completed China's new-ingredient process.

The legal consequence is direct: an ingredient not on IECIC is, by definition, a "new cosmetic ingredient" in China. Under CSAR, a new cosmetic ingredient with certain higher-risk functions must go through pre-market registration with the NMPA before use, while ingredients with other functions can proceed through a lighter filing (notification) process. According to CIRS Group's summary of the CSAR framework, the functions that trigger the stricter registration route are preservatives, colorants, hair dyes, whitening or anti-freckle (skin-lightening) agents, and sunscreen (UV filter) agents; ingredients serving other functions may generally be filed rather than registered, provided they do not present a higher risk. Where an ingredient has several functions and one of them is on the high-risk list, expect the registration route to apply, and confirm it against NMPA guidance for that ingredient.

This is the structural difference from the EU. In the EU, every ingredient can be used unless a rule in the Cosmetics Regulation says otherwise. In China, an ingredient that is neither on IECIC nor cleared through registration or filing as a new ingredient generally cannot be used at all. The inventory is not a reference list; it is closer to a gatekeeping list.

IECIC's current structure: List I, List II, and the end of fixed editions

For years the reference edition was "IECIC 2021," published by NMPA on 30 April 2021 and effective from 1 May 2021, which according to trade-press coverage (ChemLinked, CIRS Group) raised the ingredient count from roughly 8,783 to about 8,972 entries. That figure comes from secondary regulatory-affairs sources reporting on the NMPA release; it should be treated as ChemLinked/CIRS reporting on the 2021 figure, not as a live NMPA count, because NMPA has since restructured how the inventory is published.

NMPA Announcement No. 61 of 2025 (issued 23 June 2025) changed the model. The Inventory is now split into two lists. List I carries forward the 2021 IECIC content, with names standardized and remarks revised. List II holds ingredients that have separately completed China's new-ingredient registration or filing and then passed a three-year safety monitoring period with no safety concerns; at the time of that announcement, List II held two entries, N-Acetylneuraminic Acid and Beta-Alanyl Hydroxyprolyl Diaminobutyric Acid Benzylamide. NMPA also stated it will no longer issue the Inventory through periodic announcements; instead it maintains and updates the list directly on the NMPA website, under Cosmetics, Cosmetic Query, Inventory of Existing Cosmetic Ingredients. That means there is no longer a single fixed "edition" to cite the way CosIng is cited by its dataset date — the authoritative version is whatever the NMPA query tool currently shows, in Chinese.

The maximum-historical-use data NMPA dropped

IECIC 2021 had published, for many listed ingredients, a maximum historical use level — essentially a record of the highest concentration NMPA had previously seen the ingredient used at in a filed or registered product, distinct from a safety limit or an EU Annex III maximum concentration. Announcement No. 61 of 2025 states this Maximum Historical Usage Level field was removed from List I in the 2025 revision. A formulator relying on an older IECIC 2021 export or a third-party mirror that still shows these figures should confirm current status against the NMPA query tool rather than treat the historical number as current guidance.

The new-ingredient monitoring period

Once a new cosmetic ingredient is registered or filed, it enters a three-year safety monitoring period, running from the date a cosmetic product using that ingredient first completes registration or filing. During this window the registrant or filer must submit an annual safety monitoring report and report any emerging safety signal, and the registrant or filer may use the ingredient to make cosmetics during that time; whether another company can rely on that registration before the ingredient joins IECIC is a question to confirm with NMPA guidance or local counsel. If the three years pass without a safety concern, NMPA carries out a safety evaluation and, if it is satisfied, the ingredient is added to IECIC — which is exactly how List II's two 2025 entries got there. An ingredient that is mid-monitoring is not yet on IECIC, so a company that was not part of the original registration or filing cannot treat it as an existing ingredient.

How this differs from CosIng

CosIng, the European Commission's database, is explicitly informational. Its own legal notice states CosIng does not replace the official texts and has no legal value; the binding rules are Regulation (EC) No 1223/2009 itself and its Annexes II through VI. A substance can appear in CosIng — as a listed INCI name with a function, a CAS or EC number, an entry in Annex II (prohibited), III (restricted), IV (colorants), V (preservatives) or VI (UV filters), or simply as no annex hit at all — and CosIng's role is to help a reader locate and read the annex text, not to grant or withhold permission on its own.

IECIC works the other way round. Presence on IECIC (or completion of the new-ingredient route) is close to a precondition for use, not a convenience layer over separate binding rules. There is no EU analogue to "an ingredient not on the list generally cannot be sold" — in the EU an unlisted ingredient is simply unregulated by name and subject only to the general safety requirement and any category-based CMR or other restrictions that might apply.

What this means for an EU brand exporting to China

Being listed in CosIng, or even having a clean Annex II/III/IV/V/VI record in the EU, says nothing about status in China. The two checks are independent. Before formulating for the Chinese market, a brand needs to confirm, separately: (1) whether the ingredient is on the current NMPA IECIC (List I or List II, checked on the NMPA website, in Chinese); (2) whether it appears on China's own prohibited-ingredient catalogues, which are a distinct binding list from IECIC; and (3) if it is on neither, whether it needs to go through China's registration or filing route for new cosmetic ingredients — and if so, whether that route is the higher-risk registration path (preservative, colorant, hair dye, whitening/anti-freckle, or sunscreen function) or the lighter filing path.

A concrete illustration of why the two checks cannot be collapsed into one: bakuchiol (CAS 10309-37-2) is a normal CosIng entry, reference number 32053, with EU-listed functions of antimicrobial, antioxidant, and skin conditioning. Querying cosingchecker.com's China data for this same CAS number returns zero matches — no hit on the record. Under this site's own disclaimer, "No result for a jurisdiction does not mean the ingredient is permitted there": a zero match here only means the substance is absent from the prohibited-catalogue data this site holds for China, and says nothing about whether it is on IECIC, whether it needs registration or filing as a new ingredient, or whether any company already holds exclusive use of it under an active monitoring period. Only NMPA's own IECIC query tool answers that.

What cosingchecker.com's China data is, plainly stated

cosingchecker.com/regulations/cn/ holds NMPA's 2021 prohibited and restricted raw-material catalogues — binding lists of substances banned or limited in Chinese cosmetic formulas, sourced from NMPA announcements such as Announcement No. 74 of 2021. As of this writing that dataset covers 1,393 China records, all drawn from the 2021 catalogues. It does not hold IECIC. It cannot tell you whether an ingredient is on the existing-ingredients inventory, whether it needs registration or filing as a new ingredient, or what List II currently contains — those questions have to be answered on NMPA's own site, in Chinese. Use cosingchecker.com/search/ to look up a specific ingredient's EU CosIng record and cross-check its CAS or EC number, then take that identifier to NMPA's own inventory and catalogue tools for the China-side answer, rather than assuming a EU record settles the China question.

Sources

• NMPA Announcement No. 61 of 2025 on Matters Related to the Administration of the Inventory of Existing Cosmetic Ingredients (IECIC), issued 23 June 2025 — https://english.nmpa.gov.cn/2025-07/21/c_1118073.htm
• NMPA English portal, Cosmetics section (jurisdiction source page for China) — https://english.nmpa.gov.cn/2025-07/21/c_1118071.htm
• CIRS Group, China New Cosmetic Ingredient Registration and Filing (CSAR framework, high-risk functions, 3-year monitoring period) — https://www.cirs-group.com/en/cosmetics/china-new-cosmetic-ingredient-registration-and-filing
• ChemLinked, Breaking! China Releases the Inventory of Existing Cosmetic Ingredients in China 2021 (IECIC 2021 count and effective date, secondary source) — https://cosmetic.chemlinked.com/news/cosmetic-news/breaking-china-releases-the-inventory-of-existing-cosmetic-ingredients-in-china-2021-iecic-2021
• European Commission, CosIng database and legal notice (informational status, Annexes II-VI as the binding text) — https://single-market-economy.ec.europa.eu/sectors/cosmetics/cosmetic-ingredient-database_en
• Regulation (EC) No 1223/2009 on cosmetic products — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R1223-20250301
• cosingchecker.com, China regulations page (2021 prohibited/restricted catalogues, 1,393 records) — https://cosingchecker.com/regulations/cn/
• cosingchecker.com, China prohibited cosmetic ingredients list explained — https://cosingchecker.com/blogs/china-prohibited-cosmetic-ingredients-list-explained/
• cosingchecker.com API, live stats — https://cosingchecker.com/api/v1/stats/
• cosingchecker.com API, bakuchiol ingredient record and China jurisdiction check — https://cosingchecker.com/api/v1/ingredients/32053-bakuchiol/jurisdictions/