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Guide
What if an ingredient is not in the Inventory of Existing Cosmetic Ingredients
If a formula ingredient cannot be found in the current Inventory of Existing Cosmetic Ingredients in China (IECIC), you generally cannot enter it as an ordinary existing ingredient in a product filing or registration. Such an ingredient is usually a new cosmetic ingredient. It should first complete new-ingredient registration or filing, and only then be used within its approved purpose, site of use, level and product type. Whether it is truly new, and whether it requires registration or filing, depends on the current inventory, the substance’s composition and risk, and the rules then in force.
How to judge before you redesign the formula
Check the standard Chinese name, INCI name or English name against the current inventory published by the NMPA. Aliases, old names or different ways of splitting a mixture cause false “not found” results. For mixtures, assess each component. If the ingredient is an already registered or filed new ingredient still in its monitoring period, use the registered or filed name and follow the monitoring-period conditions.
What happens next
Higher-risk new ingredients are registered; other new ingredients are filed. A new ingredient then has a three-year safety-monitoring period starting from the first product that uses it and obtains registration or completes filing. During that period, cosmetics that use the ingredient generally submit a full safety-assessment report. Children’s cosmetics must not use new ingredients that are still being monitored. Unregistered or unfiled new ingredients must not appear in a product formula.
Cautions
Do not rename an unmatched ingredient so that it resembles a nearby inventory entry. We do not market ingredient submission codes as a service. Under Announcement No. 70 of 2026, companies keep raw-material safety information on file instead of entering a submission code in the system.
Questions we are often asked
Can we replace the unmatched ingredient with “fragrance” or a trade blend name?
Only if that description is true and each component that must be identified can be matched to the inventory or to a duly registered or filed new ingredient. A trade name is not itself an inventory listing.
Does Jinshang register new ingredients for clients?
We help check whether an ingredient can be used in a product filing or registration. We do not promote new-ingredient registration or filing, or submission codes, as a separate service line.
Next step
Discuss your China market path
Tell us whether you plan to import finished goods or manufacture in mainland China, and what the product claims. We will outline the likely filing or registration path. Testing, where needed, is arranged with partner laboratories.
Contact us