China IECIC: Lists, Verification, and Monitoring Period

China’s Inventory of Existing Cosmetic Ingredients, known as the IECIC, is the official whitelist of substances approved for use in cosmetic products made in or imported into China. The 2021 edition contains 8,972 ingredients. Anything not on the list is automatically treated as a “new cosmetic ingredient” and cannot be used in a cosmetic product until it clears a separate approval process with the National Medical Products Administration (NMPA). Whether a formulation moves through customs in days or gets stuck in a multi-year review usually comes down to whether every ingredient in it appears in this inventory under the correct name and usage category.

Why the Inventory Sets the Regulatory Gate

The Regulations on the Supervision and Administration of Cosmetics (CSAR) took effect on January 1, 2021, and established the legal line between “existing” and “new” ingredients. Existing ingredients on the IECIC can be used through a relatively streamlined filing or notification process, so long as the formulation respects concentration limits and usage restrictions. New ingredients that have never appeared in the inventory must go through either formal registration or a separate filing with the NMPA, depending on their risk category. That single distinction is the most important regulatory gate for any company entering the Chinese cosmetics market.

List I and List II After the 2025 Restructuring

In July 2025, the NMPA split the IECIC into two sublists. List I is a refined version of the 2021 inventory, with standardized Chinese, INCI, and English names, and remarks aligned with the Technical Specification for the Safety of Cosmetics. The “Maximum Historical Usage Level” field was removed from List I entries.¹

List II is where new cosmetic ingredients land after they complete a three-year safety monitoring period and pass regulatory review. The first two ingredients added to List II were N-Acetylneuraminic Acid and β-Alanyl Hydroxyprolyl Diaminobutyric Acid Benzylamide.¹

One practical change: the NMPA will no longer publish inventory updates as formal announcements. Additions, corrections, and refinements now appear on the NMPA website under Cosmetics → Cosmetic Query → Inventory of Existing Cosmetic Ingredients. The agency also established a dynamic adjustment mechanism, meaning the inventory is updated continuously rather than in scheduled batches. Companies should monitor the NMPA website directly rather than waiting for a next edition.

How to Verify an Ingredient

Every ingredient in the IECIC is identified by three data points: a Standard Chinese Name (the primary legal identifier used at customs), an International Nomenclature Cosmetic Ingredient (INCI) name, and a unique ID number that distinguishes it from chemically similar compounds. All three must match the inventory entry exactly. A mismatch in naming or categorization means the substance is legally treated as a new ingredient, no matter how similar it looks to an existing entry.

The NMPA’s website hosts the official query tool. Third-party databases such as ChinaCosIng allow English-language searches and can flag whether a substance appears on any restricted or prohibited lists. Those are useful for preliminary screening, but the NMPA database is the authoritative source and the one customs officials reference.

Approved usage category also matters. A substance may be cleared for rinse-off products such as shampoos but not for leave-on products such as moisturizers. Using it outside its approved category is functionally the same as using an unapproved ingredient.

Being Listed Is Not the Same as Being Unrestricted

Appearance in the IECIC does not mean an ingredient can be used at any concentration or in any product type. The Safety and Technical Standards for Cosmetics (STSC) imposes specific caps and conditions through several controlled lists:

Restricted ingredients, usable only within defined concentration limits, application types, or labeling requirements.
Permitted preservatives, a closed list with maximum concentrations.
Permitted UV filters, with maximum concentration requirements.
Permitted colorants, some limited to specific product types.
Permitted hair dyes, with concentration and usage restrictions.

The NMPA revises these periodically, and reformulation timelines often exceed a year, so tracking the changes well in advance matters as much as the initial verification.

When an Ingredient Is Not on the List

If a substance is not in the IECIC, the path forward depends on how the NMPA classifies its risk. New ingredients serving as preservatives, sunscreens, colorants, hair dyes, or spot correctors and whitening agents must go through formal registration, which requires NMPA review and approval before the ingredient can be used.² All other new ingredients follow the filing pathway, which is complete once the applicant submits the required documentation. Filing is less burdensome than registration, but the documentation requirements are still substantial.

One detail catches many companies off guard. Adjusting the intended use, safe dosage, or other parameters of an ingredient already in the IECIC also triggers the new ingredient process. If you want to use an existing ingredient at a higher concentration than historically approved, or in a product category it has not previously been used in, you may need to go through registration or filing as if it were entirely new.²

What the Application Dossier Requires

Whether registering or filing, the applicant must assemble a comprehensive dossier. The core is toxicological test data covering, at minimum, acute toxicity, skin irritation, and mutagenicity. The specific tests required scale with the ingredient’s risk classification.

Beyond toxicology, the dossier must include:

Manufacturing process details, including chemical purity specifications, potential contaminants, and production methods.
Physical and chemical properties such as molecular weight, structure, solubility, and stability data.
A safety assessment report evaluating the ingredient under its intended conditions of use, following the NMPA’s technical guidance.
Functional proof that the ingredient does what the formulator claims, whether moisturizing, UV protection, or another effect.
Legal representative information, including contact details and a power of attorney for any agents handling the submission.

Test results must come from laboratories with appropriate certifications for cosmetic safety testing. Incomplete or inaccurate submissions are routinely rejected, and resubmission resets the review clock. This is where most delays originate.

The Three-Year Monitoring Period

Completed dossiers are submitted through the NMPA’s online platform, which requires a verified account and authorized digital signatures on all documents. Once the submission is accepted, the ingredient enters a mandatory three-year safety monitoring period. The clock starts from the date when cosmetics using the new ingredient are first registered or filed, not from the date of the ingredient submission itself.²

During this period, the registrant or filing person must submit an annual report summarizing use and any safety concerns. The report is due within 30 working days before the end of each yearly period of monitoring.² Beyond the annual filing, the applicant must immediately report to the NMPA’s technical assessment agency if:

Serious or group adverse reactions are suspected to be linked to similar ingredients in any country.
Another country raises safety standards, increases restrictions, or bans a similar ingredient.
Any other circumstance affects the ingredient’s safety profile.

If no safety issues surface, the ingredient is evaluated for inclusion in the IECIC. Under the 2025 structure, qualifying ingredients are added to List II and become available for use by all manufacturers without further restriction.¹

Extra Steps for Foreign Companies

Foreign companies cannot submit new ingredient applications directly. They must appoint a domestic responsible person in China to act as their legal representative for all interactions with the NMPA. The authorization letter appointing this representative must be notarized in the company’s home country.

China began accepting apostilles in November 2023. For members of the Hague Apostille Convention, an Apostille Certificate now satisfies the authentication requirement, replacing the older dual consular legalization process. Companies in non-member countries still need to go through notarization at home followed by authentication at a Chinese embassy or consulate. Documents commonly requiring this treatment include the domestic responsible person’s authorization letter and, where original GMP certificates are unavailable, notarized copies of quality management system documentation.

Consequences of Getting It Wrong

Using an ingredient not listed in the IECIC without completing the new ingredient registration or filing process carries significant consequences under CSAR. Violations can lead to product seizure, administrative fines, and orders to halt production or sales. The Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics further specify that GMP violations discovered during inspections are punishable under CSAR, though minor violations corrected promptly may be exempt from administrative penalties.³

The real cost usually extends beyond the fine. A rejected filing means reformulation, retesting, and resubmission, which can delay market entry by a year or more. For imported products, a customs rejection based on an IECIC mismatch can trigger enhanced scrutiny on future shipments from the same company. Verifying every ingredient against the current inventory before manufacturing or shipping is far cheaper than working through the consequences later.

1
National Medical Products Administration. Announcement on Matters Related to the Administration of the Inventory of Existing Cosmetic Ingredients (No. 61 of 2025)
2
National Medical Products Administration. The Provisions for Registration and Filing of Cosmetics
3
National Medical Products Administration. Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics