CIRS Group Maps China's New Cosmetic Ingredient Filings Through September 2026

CIRS Group published its September 2026 analysis of new cosmetic ingredient filing status in China on September 30, covering the National Medical Products Administration (NMPA) notification pipeline under the country's 2021 cosmetics framework.

The report lands inside a four-week regulatory window that runs through the end of China's National Day holiday on October 8. Formulators targeting Q1 2027 launches now have roughly 90 days to clear any ingredient filings ahead of China's pre-market notification clock.

What does the September 2026 update cover?

CIRS tracks filings submitted to the NMPA's new cosmetic ingredient (NCI) register, the dossier pathway introduced when China's Cosmetics Supervision and Regulation took effect January 1, 2021. Companies file three categories under this system:

• New chemical entities not previously used in any cosmetic product
• Ingredients with new use scopes or expanded concentration limits
• Ingredients sourced from new raw material suppliers requiring safety re-assessment

The September report catalogs filings submitted and completed review through September 30, 2026. CIRS publishes monthly updates tracking notification acceptance, safety assessment outcomes and any ingredient reclassifications the NMPA issues.

Why timing matters for compliance teams

China runs on a notification-based system, not an approval-based one. Brands submit dossiers, the NMPA reviews within defined windows, and listings move to the public registry after safety clearance. Miss a filing window and a 2027 launch slips to 2028.

The September 30 cut-off carries weight. Any NCI submitted before that date enters the review queue for Q4 2026 clearance decisions. Filings lodged during October 1-15 typically see review times extended by the holiday closure, adding 7-10 working days to standard timelines.

Sophie Lindqvist, writing for INCI File, has covered NMPA filings since the 2021 framework launch.

What filings typically move through the pipeline

CIRS reports separate three regulatory tracks that compliance teams monitor simultaneously:

• Ordinary NCI filings: standard notification for ingredients with established safety profiles
• High-risk NCI filings: require full toxicology dossiers and 3-year safety use monitoring
• Existing ingredient reclassifications: NMPA-initiated reviews of substances already on the market

Each track carries different review timelines. Ordinary filings clear in 45-90 working days. High-risk submissions run 6-12 months from dossier acceptance to final listing.

What's the next data point to watch?

Watch the NMPA's October 2026 monthly disclosure, expected mid-November, for completed NCI listings from the September queue. CIRS Group's October analysis will publish by month's end. Formulators awaiting ingredient clearance for Q1 2027 product launches should confirm their September submissions cleared the initial review stage by November 15.