China's National Medical Products Administration has officially launched the pilot program for electronic labeling of cosmetics, with regions like Beijing and Guangdong taking the lead in a three-year trial period. This policy mandates that pilot cosmetics must display Chinese label information via electronic tags, including core data such as product name, ingredient list, production batch number, and registration/filing number, achieving full-chain traceability with "one item, one code." This marks the official entry of China's cosmetics regulation into a new digital and transparent phase, setting a new benchmark for high-quality industry development.
Policy Transformation: From Regulatory Approval to a New Blueprint for Full Implementation
In recent years, electronic labeling for cosmetics has existed in a gray area where it is "legally recognized but lacks detailed implementation rules." Although the 2021 Regulations on the Supervision and Administration of Cosmetics acknowledged the legality of electronic labels, specific implementation guidelines remained unresolved.
The pilot program launched on February 1, 2026, provides the industry with clear"official guidelines". The fundamental difference from previous policies lies in the explicit definition of four core elements: scope, process, technology, and supervision in this pilot.
The pilot period is set for three years, indicating that by early 2029, the industry will undergo a comprehensive evaluation and potential nationwide rollout. For cosmetics companies and related technology service providers, these three years represent a valuable window for capacity building.
Technical specifications: QR codes become digital IDs for products
According to technical specifications, the QR code on electronic cosmetics labels will carry far more functions than traditional labels. It serves not only as an information display window but also as an entry point for full product lifecycle management. The specifications require QR codes to have high fault tolerance and damage resistance, ensuring they remain scannable even with minor packaging damage. This guarantees the durability of cosmetic identification during transportation, warehousing, and sales.
More importantly, the policy explicitly allows QR codes to redirect to secondary pages built by enterprises. This regulation opens a policy pathway for the in-depth application of one-item-one-code technology. Enterprises can comply with basic information display requirements while integrating value-added services such as anti-counterfeiting verification, product traceability, ingredient interpretation, and usage guidance. This necessitates comprehensive solutions that meet both government regulatory requirements and commercial needs of businesses. Simple QR code generation services can no longer satisfy market demands,requiring systems that integrate compliance, anti-counterfeiting, and marketing.It will become the industry standard.
Practical guide: A four-step path for enterprises to embrace electronic labels
Facing the electronic label pilot policy, cosmetic companies need to establish a clear implementation path. This process can be broken down into four key steps:Compliance assessment, system setup, content management, application expansion。
Companies need to verify their entity qualifications registered in pilot areas, evaluate the compliance of existing product labels, and identify content and formats requiring adjustments. Special attention should be paid to ensuring that product names, ingredient labeling, and other details are completely consistent with the filing information.
During the system setup phase, companies can choose to build it themselves or collaborate with professional technical service providers. The system must meet the requirements of the "Dataset" and "QR Code Technical Specifications."
Content management is an ongoing process. Enterprises need to establish mechanisms for creating, reviewing, and updating electronic label content to ensure information accuracy and timeliness. Especially when product formulations change, electronic label content must be updated accordingly.
Application expansion is the stage of value realization. On the basis of meeting basic compliance requirements, enterprises can leverage unique identification codes to achieve value-added functions such as anti-counterfeiting traceability, membership marketing, and consumer insights.Compliance and commercial value are not contradictorybut can mutually reinforce each other.