On August 26, 2024, Shanghai Municipal Medical Products Administration issued the Guidelines for the Standardized Operation of Cosmetic Samples in Shanghai (Draft) (the Guidelines), which is open for public comment until September 18, 2024. As per the Guidelines, cosmetic samples are defined as cosmetics intended for promotional purposes, including free trials, gifts, and exchanges, and are smaller than full-size products.

In terms of regulatory compliance, cosmetic samples are required to be registered or notified, and fulfill the specified labeling requirements. Regarding the operation of cosmetic samples, the Guidelines clarifies the obligations that cosmetic sample operators shall fulfill, including establishing and implementing a material purchase inspection record system, assisting relevant departments in monitoring cosmetics adverse reactions, cooperating in the implementation of cosmetics recalls, etc. Notably, the Guidelines also clarifies the compliance responsibilities of cosmetics registrants and notifiers, who are required to establish and implement a product sales record system for products including cosmetic samples.