Slows you downChinaBeauty & personal care

China is piloting labels that are not on the product

China’s National Medical Products Administration notified a pilot program for electronic labelling of cosmetics on 28 November 2025 as GYJZ [2025] No.16, made under the Regulations on Supervision and Administration of Cosmetics, and published Requirements for the pilot on 24 December 2025 covering cosmetics including toothpaste.

Every other market in this index answers the disclosure question with print, so a brand carrying one artwork file across borders is solving a problem China is in the middle of deciding it does not have.

78

78 of a possible 97Tier A, primary document or measured outcome. Nothing at this tier is allowed past 97, however good it looks.

Verified August 5, 2026Rechecked every 90 days, next by November 3, 2026.

Structure

Held since November 28, 2025How the market is physically or commercially arranged. The earliest date we are willing to say this held. It may well have been true before that; we do not backdate a record past the evidence we have read. Supported, version 1.

This entry is wrong if

NMPA withdraws or completes the pilot without adopting electronic labelling, or the notice number GYJZ [2025] No.16 is shown to concern something other than cosmetic electronic labelling.

Written before the record was published, not after. If you can show this, send it to hello@tryorbt.com and the correction goes on the record with the entry.

Evidence

  1. Tier Aregulation

    National Medical Products Administration (China): Cosmetics: announcements and notices

    NMPA Notice on Conducting a Pilot Program for Electronic Labeling of Cosmetics GYJZ [2025] No.16 2025-11-28. The National Medical Products Administration (NMPA) has decided to carry out a pilot program for cosmetic electronic labeling in accordance with the Regulations on Supervision and Administration of Cosmetics.

    Read 2026-08-05 · No stated terms · page hash 54cdc0ec9c38

  2. Tier Aregulation

    National Medical Products Administration (China): Cosmetics: announcements and notices

    Requirements for the Pilot Program of Electronic Labels for Cosmetics 2025-12-24. To regulate the pilot program for electronic labels for cosmetics (including toothpaste, hereinafter referred to as “cosmetics”), these Requirements are formulated in accordance with the provisions of the Regulations on Supervision and Administration of Cosmetics

    The second document is a month later than the notice and is what turns the pilot into something a company can act on. Both are summaries printed on the index page; neither full text was retrieved.

    Read 2026-08-05 · No stated terms · page hash 54cdc0ec9c38

History

  1. v1created

    Initial entry from the regulator's English announcements index, read 2026-08-05. The underlying notice and requirements documents were not retrieved, and the confidence is set below the tier-A ceiling for that reason.

Append-only. Nothing in this list is edited or removed once written, including the entries that record our own mistakes. Every change to every record is on the corrections page, and the same log is in entries.json under revisions.

  • china
  • nmpa
  • labelling
  • packaging
  • digital
  • market-entry
  • beauty

Cite this entry

“China is piloting labels that are not on the product”, The Orbt Market Index 0.1.0, entry omr:cn:the-label-is-being-moved-off-the-pack, retrieved September 9, 2026, https://tryorbt.com/markets/entry/cn--the-label-is-being-moved-off-the-pack. Dataset: https://doi.org/10.5281/zenodo.22679129

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Free to quote, cite and act on. Not to resell or redistribute — the sources ask that of us, and each one’s terms are named. Machine-readable: entries.json carries this record under the id omr:cn:the-label-is-being-moved-off-the-pack, with the same evidence and falsifier.

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