China Releases Three-Year Action Plan to Upgrade Cosmetic Production Quality Management Systems (2026–2028)

On December 12, 2025, China's National Medical Products Administration (NMPA) issued the Action Plan for Improving the Production Quality Management Systems of Cosmetic Enterprises (2026–2028). ¹ The Plan aims to address persistent weaknesses in the quality management of registrants, notifiers, and contract manufacturers, with the ultimate goal of strengthening public safety and supporting the high-quality development of the cosmetic industry.

By the end of 2028, the implementation of the Plan is expected to result in:

• stronger corporate accountability for product quality and safety;

• more robust and effective quality management systems;

• enhanced competency of key responsible personnel;

• improved quality and safety management and risk control level; and

• more professional regulatory oversight.

The Plan also supports the formation of a multi-stakeholder governance framework involving enterprises, regulators, industry associations, consumers, media, and legal mechanisms. Ultimately, China aims to boost innovation, competitiveness, and brand strength across its cosmetic sector.

Key Highlights of the Three-Year Action Plan

The Plan defines twelve major tasks under three overarching themes: strengthening enterprise capabilities, promoting high-quality industry development, and enhancing regulatory capacity. The key measures are summarized below.

1. Strengthening Enterprise Quality System Capabilities

1.1 Establishing Clear Quality Problem Lists and Corrective Actions (by June 2026)

Provincial MPAs must identify common deficiencies across cosmetic enterprises—focusing on the completeness of quality documentation, consistency between production processes and registration/notification dossiers, ingredient compliance, performance of key personnel, internal inspection of quality system, oversight of contract manufacturing, and batch release procedures.

By June 2026, each province must develop a regional problem list with corresponding corrective actions and phased timelines.

1.2 Targeted Regulatory Guidance Based on Enterprise Risk and Needs

Provincial MPAs are required to build enterprise guidance ledgers and develop tailored guidance plans considering enterprise size, risk control capability, and specific needs. Guidance should prioritize:

• strengthening quality system documentation;

• improving the effectiveness of system operation and self-inspection;

• enhancing accountability and management competence of key personnel.

Stronger support should be given to children's cosmetics manufacturers, special cosmetics enterprises, and small and medium-sized enterprises (SMEs). Provincial MPAs should adopt "one enterprise, one policy" and "service-to-enterprise" mechanisms.

1.3 Inclusion of Quality Accountability in Routine Supervision

During routine inspections, regulators will place particular emphasis on how enterprises fulfill their quality and safety responsibilities and how key responsible personnel perform their duties.

1.4 Strengthening Enterprise Risk Management Mechanisms

Enterprises must establish dynamic quality and safety risk control mechanisms covering registration/notification dossiers review, production consistency review, batch release, cause-based self-inspection, and full quality system self-inspection.

1.5 Encouraging Internal Risk Reporting and Proactive Mitigation

Enterprises should establish internal mechanisms for employees to report quality risks. Companies are expected to conduct continuous and comprehensive risk assessments, address confirmed issues promptly, and implement preventive measures.

2. Driving High-Quality Development of the Cosmetic Industry

2.1 Innovation in Quality Management and Smart Manufacturing

Provincial MPAs are encouraged to explore innovative models, such as applying unified quality system requirements to external warehouses.

Enterprises are encouraged to adopt intelligent and diversified production methods to increase quality consistency and manufacturing efficiency.

2.2 Strengthening Risk-Based Supervision and Accountability

Regulators must adopt problem-oriented inspection plans and focus oversight on the construction and operation of enterprise quality systems. When deficiencies are found:

• enterprises must rectify issues within specified timelines;

• follow-up verification will be conducted; and

• for serious violations, the rule of "punishing individuals for illegal acts" will be strictly enforced, targeting legal representatives, main responsible personnel, and other directly responsible personnel.

2.3 Developing Replicable Best Practices and Supporting Industrial Clusters

Provincial MPAs should identify enterprises with well-functioning quality systems and summarize best practices. By the end of 2028, at least 50 replicable and scalable best-practice cases must be established nationwide.

Regions with strong industrial clusters will receive targeted policy guidance to support transformation toward standardization, intelligent manufacturing, and internationalization, fostering competitive industry leaders.

3. Enhancing Regulatory Capacity and Service Levels

3.1 Advancing Tiered and Categorized Regulation

Provincial MPAs are encouraged to refine mechanisms for classifying enterprises based on quality system maturity, risk control capacity, and credit performance. Routine inspections and licensing inspections will be integrated into "multi-in-one" inspections, reducing duplication and inspection burden.

3.2 Harmonizing Inspection Criteria and Professional Standards

Regulators will analyze common issues related to the implementation of Good Manufacturing Practices for Cosmetics. Inspection criteria will be unified through policy Q&As, training programs, and case-based learning.

3.3 Accelerating Digital Transformation in Quality Management

Enterprises are encouraged to incorporate AI, IoT, and other advanced technologies into production quality management. China aims to promote full-chain intelligent control systems—from ingredient entry to intelligent manufacturing and traceability—to strengthen product safety foundations and enhance overall industry competitiveness.