Cosmetics E-Labeling Pilot: Enterprise Responses & New Policy Key Points

On October 20th, the NMPA issued the "Notice on Launching the Pilot Program of Cosmetics Electronic Labeling". Starting from February 1st, 2026, a 3-year pilot program will be carried out in Beijing, Shanghai, Zhejiang Province, Shandong Province, Guangdong Province, and Chongqing Municipality, where cosmetics Chinese labels will be marked through electronic labeling.

The implementation of the electronic labeling policy marks that the management of cosmetics labels has entered a new digital stage. This article sorts out the core content of the policy and interprets its impacts on enterprises as well as corresponding response strategies.

What is a cosmetics electronic label?

A cosmetics electronic label (hereinafter referred to as the "electronic label") refers to the relevant content of a cosmetics Chinese label stored through a certain electronic storage mechanism, as well as the corresponding QR code generated by an information system. The electronic label shall have a convenient reading function, enabling consumers to directly read it by scanning the code with common communication or payment software installed on smartphones to obtain the product's Chinese label information. The electronic label is an integral part of the cosmetics label.

The QR code of the electronic label shall be marked in a prominent position on the visible surface of the sales package. For products with an affixed Chinese label, the QR code of the electronic label shall be marked in a prominent position on the Chinese label. For products with an outer packaging box, pilot enterprises are encouraged to simultaneously use the electronic label on the packaging container that is in direct contact with the product contents.

In-depth Interpretation and Comparison of the Core Requirements for Electronic Labels

However, electronic labels do not simply replace all paper-based information with QR codes; instead, they establish a two-tier label system featuring "streamlined marking on physical labels + complete display via electronic labels".

Before the launch of pilot products, enterprises shall upload the following materials to the Cosmetics Registration and Filing Information Service Platform：

• Data structure coding information of the electronic label URL

• Display content of the electronic label

• Pictures of the product's sales package

Change in Label Content Structure:From "Full Information on the Container" to "Combination of Physical and Electronic Labels"

The following table clearly compares the fundamental changes in the labeling positions of content under the new and old label models:

For instance, key information such as product name and net content must still be marked on physical labels, focusing on core details for product identification and safety.

Electronic labels, on the other hand, carry information that requires completeness, extensibility, and updatability. For example, the full list of ingredients can be moved to electronic labels, freeing up space on physical labels. Regarding the labeling of usage instructions, enterprises can leverage the flexibility of electronic labels to provide more comprehensive explanations, video links, interpretations of innovative terms, and other content, thereby enhancing the user experience.

Technical and Compliance Requirements for the Electronic Label System

Beyond content requirements, electronic labels impose higher demands on enterprises' technical capabilities and ongoing compliance.

Standardization Requirements for Data Structure

The data structure of the QR code for cosmetics electronic labels adopts a URL-based format, consisting of a network service address (mandatory), a product identification (mandatory) unit data string, and a production identification (optional) unit data string in sequence.

• Product Identification: A unique code specific to a cosmetic product category (down to the cosmetics filing number or registration certificate number) or a specific specification within a category.

• Production Identification: A code used to identify data related to the cosmetics production process (e.g., production batch number, etc.).

The key decision point for enterprises lies in whether to refine the electronic label to include the "production identification". If only the product identification is included, the dynamic production identification information must still be marked on the physical label.

Cosmetics electronic labeling marks a key step in the digital upgrade of the industry. It not only makes it more convenient for consumers to access product information, but also offers enterprises a more flexible way to present labels. However, compliance, system stability, and data authenticity remain non-negotiable bottom lines that enterprises must strictly uphold. Relevant businesses can launch system development and label adjustments early, seize the opportunities of this pilot program, and boost their brand competitiveness.

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