China's Prohibited Cosmetic Ingredient Lists Explained

China does not regulate cosmetic ingredients through a single annex the way the EU does. The prohibited-ingredient rules sit inside a technical standard, are split across two separate catalogues by origin (synthetic chemical versus plant or animal derived), and interact with a second, independent inventory that decides whether an ingredient counts as "new" at all. Formulators who treat China's system as an EU Annex II equivalent - one list, one status, done - miss most of how it actually works. This article sets out the legal structure, what the current catalogues contain, how they relate to new-ingredient filing, and where the translation and sourcing caveats sit.

The legal framework: CSAR and the NMPA

China's cosmetics law changed structurally in 2021. The Regulations on Supervision and Administration of Cosmetics (State Council Decree No. 727), promulgated on 29 June 2020, took effect on 1 January 2021 and was the first comprehensive revision of China's cosmetics administration since 1989. CSAR replaced the older administrative regulation and gave the National Medical Products Administration (NMPA) its current authority over cosmetic registration, filing, ingredient safety review and enforcement.

CSAR itself does not list banned substances by name. It sets the legal obligations - registration and notification duties, safety assessment requirements, penalties - and delegates the substance-level technical detail to standards and catalogues issued under it. That is where the prohibited-ingredient lists live.

The Safety and Technical Standards and the 2021 catalogue update

The technical standard is the Safety and Technical Standards for Cosmetics (2015 edition), which originally carried the prohibited-substance tables as two annexed tables: banned chemical components and banned plant/animal-derived components. In May 2021, the NMPA issued an announcement updating both tables, replacing them with a standalone Catalogue of Raw Materials Banned for Cosmetics (chemical substances) and a Catalogue of Plant (Animal) Raw Materials Banned for Cosmetics. Secondary reporting on the official announcement (including a reposting via China Daily's NMPA subsite) numbers it Announcement No. 74 of 2021; the NMPA's own English-language page confirms the substance - the two revised catalogues, adopted by the Expert Committee of Cosmetics Standards - without restating the announcement number on that page, so treat the "No. 74" numbering as secondary-sourced rather than confirmed on the primary English text itself.

The operative rule, as stated in the NMPA's announcement, is straightforward: as of the date of promulgation, cosmetic registrants and filing applicants must not manufacture or import cosmetics whose formula contains a raw material listed in either catalogue. The record on cosingchecker.com/regulations/cn/ carries that same distinction - the current published dataset attributes every entry to "NMPA Announcement No. 74 of 2021, effective 2021-05-26," split by catalogue into chemical and plant/animal-derived origin.

What the current dataset holds

As of this writing, the China dataset on cosingchecker.com/regulations/cn/ holds 1,393 published rules, and every one of them currently carries the status "prohibited" - the dataset does not yet carry restricted-status China entries. Of those 1,393 records, 1,284 come from the chemical catalogue and 109 from the plant (animal) catalogue, matching the two-table structure described above.

Four chemical-catalogue examples, each with a CAS number and matched against the EU dataset:

• 1,1,2-Trichloroethane (CAS 79-00-5) - prohibited in China's chemical catalogue, entry 5; also EU Annex II entry 1169, classified Carcinogenic Cat. 2.
• 1,2,3-Trichloropropane (CAS 96-18-4) - prohibited in China's chemical catalogue, entry 10; also EU Annex II entry 1141, classified Carcinogenic Cat. 1B and Reprotoxic Cat. 1B.
• 1,2,3,4,5,6-Hexachlorocyclohexane / BHC-ISO (CAS 58-89-9) - prohibited in China's chemical catalogue, entry 9; also EU Annex II entry 195.
• 1,1,3,3,5-Pentamethyl-4,6-dinitroindane, the musk Moskene (CAS 116-66-5) - prohibited in China's chemical catalogue, entry 6; also EU Annex II entry 421.

The plant/animal catalogue is a different kind of list: entries identified by Latin binomial and Chinese common name rather than CAS number, since most have none. Entry 106, for example, is Tagetes erecta flower extract and Tagetes erecta flower oil (marigold). Entry 5 is Alocasia odora (synonym Alocasia macrorrhiza), a toxic ornamental plant with no CAS number and no matching entry in the EU Annex II records held here. That is a statement about this dataset, not proof that no EU rule touches it, but it shows how much of the plant catalogue has no obvious EU counterpart to cross-check against.

How this relates to IECIC and new-ingredient filing

The prohibited catalogues answer one question: is this specific raw material banned outright. They say nothing about whether an ingredient that is not banned can be used freely. That second question runs through a separate mechanism - the Inventory of Existing Cosmetic Ingredients in China (IECIC).

The NMPA issued the Catalogue of Used Cosmetic Raw Materials (Edition 2021) - the current IECIC - effective from 1 May 2021, revising the prior 2015 directory. Regulatory-consultancy reporting on the official release (CIRS Group) puts the final count at 8,972 ingredients, up from 8,783 in the prior inventory, after the draft version's 8,980 entries were reconciled to remove 16 duplicates and add 8 new ingredients. An ingredient's presence on IECIC is what determines whether it is treated as an existing ingredient for filing purposes; an ingredient absent from IECIC is a "new cosmetic ingredient" under CSAR and is subject to mandatory pre-market registration (for higher-risk categories, such as preservatives, sunscreens, colorants and biological-origin materials) or notification (for others) with the NMPA before it can be used in a marketed formula.

The IECIC has also stopped being a static, edition-numbered document. A later NMPA notice (dated 21 July 2025 on the NMPA's English site) describes a restructuring into a two-part inventory - a List I based on the 2021 baseline with standardized nomenclature, and a List II of ingredients added after completing a three-year post-approval safety monitoring period - maintained through a "dynamic adjustment" mechanism on the NMPA's cosmetics query portal rather than through periodic numbered announcements. That notice records two ingredients added under this mechanism: N-Acetylneuraminic Acid and beta-Alanyl Hydroxyprolyl Diaminobutyric Acid Benzylamide. The practical consequence for formulators: the IECIC status of an ingredient can change between snapshots without a new numbered announcement to search for, so a dated IECIC copy - like any dated regulatory snapshot - needs revalidating against the live NMPA portal before a filing decision, not just checked once.

Source language and translation caveats

The controlling text for all of this is Chinese. The NMPA publishes an English-language section of its own site, and it is useful for tracking announcement dates and scope, but it does not appear to republish full catalogue tables with the same completeness as the Chinese originals. The underlying record for the current China dataset on cosingchecker.com points to a Hong Kong Trade and Industry Department circular rather than a direct NMPA PDF. The circular reproduces NMPA Announcement No. 74 of 2021 and both catalogues in the original Chinese, excerpted from the NMPA website it cites, and that record is flagged in the data with a translation-status field so the distinction between primary Chinese text and secondary English republication stays visible. Chinese plant and chemical names in the catalogues also do not always map one-to-one onto INCI or CAS identifiers; several plant-catalogue entries carry no CAS number at all, and Latin binomial names can have accepted synonyms (as with Alocasia odora / Alocasia macrorrhiza above), which is a common source of mismatched cross-references in secondary compilations.

Comparing China's lists with EU Annex II

Structurally, the two systems solve a similar problem in different ways. EU Annex II, under Regulation (EC) 1223/2009, is a single directly applicable list of substances prohibited in cosmetic products, currently holding 1,739 entries in the dataset on cosingchecker.com/annex/II/, with the great majority carrying a CAS number. China splits the same underlying idea - substances that may not appear in a cosmetic formula - into two lists by material origin, chemical versus botanical/zoological, reflecting a standards-and-catalogue drafting tradition rather than a single omnibus regulation.

Where the two lists overlap, they tend to agree: the four chemical examples above (trichloroethane, trichloropropane, the BHC pesticide, and musk Moskene) are prohibited on both sides, and CMR-classified industrial chemicals banned in the EU tend to also appear in China's chemical catalogue. Where they diverge is mostly at the edges each system was built to cover that the other was not: China's plant/animal catalogue includes toxic or traditionally-known-hazardous botanicals, like Alocasia odora, that have no reason to appear in an EU annex built around a different substance-nomination process, and the EU annexes carry CMR classification detail, SCCS opinion references and concentration-limit machinery for restricted substances that China's binary prohibited/not-prohibited catalogue structure does not replicate. Neither list is a subset of the other, and a substance's absence from China's prohibited catalogues says nothing about its status in the EU or vice versa. cosingchecker.com/market-divergence/ is built to surface these substance-by-substance gaps rather than assuming parity between markets.

Using this data without overreading it

An imported China record on cosingchecker.com is identity evidence for a catalogue entry - the substance name, its CAS number where one exists, and the announcement it comes from - not a live legal opinion and not a complete map of Chinese cosmetics law. A prohibited listing is a strong signal to exclude that raw material from a China-bound formula. An ingredient's absence from both the chemical and plant/animal prohibited catalogues is not proof that it is permitted: it may still be a new ingredient requiring registration or notification if it is not on the current IECIC, and the IECIC itself now updates through a rolling mechanism rather than fixed annual editions. Given the source-language gap described above, any formulation decision that turns on a specific China entry should be checked against the current Chinese-language NMPA text or a qualified in-market regulatory contact before filing, not against a snapshot alone.

Sources

• NMPA Announcement on Updating the Catalogue of Raw Materials Banned for Cosmetics — http://english.nmpa.gov.cn/2021-05/28/c_655126.htm
• NMPA Announcement on Issuing the Catalogue of Used Cosmetic Raw Materials (Edition 2021) — https://english.nmpa.gov.cn/2021-04/30/c_655124.htm
• NMPA notice on the restructured cosmetic ingredient inventory (List I / List II, dynamic adjustment) — https://english.nmpa.gov.cn/2025-07/21/c_1118071.htm
• NMPA English-language regulations index — https://english.nmpa.gov.cn/2020-06/29/c_528633.htm
• Hong Kong Trade and Industry Department circular reproducing NMPA Announcement No. 74 of 2021 and both catalogues in Chinese — https://www.tid.gov.hk/en/tradecircular/files/2021/ci2021371a.pdf
• China Daily NMPA subsite reposting of NMPA Announcement No. 74 of 2021 (secondary, confirms announcement number) — http://subsites.chinadaily.com.cn/nmpa/2021-05/28/c_644359.htm
• CIRS Group: Inventories of Cosmetic Ingredients in China are Fully Updated (secondary, IECIC 2021 counts) — https://www.cirs-group.com/en/cosmetics/inventories-of-cosmetic-ingredients-in-china-are-fully-updated
• Regulation (EC) No 1223/2009 on cosmetic products, Annex II — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009R1223-20250301