Same formula, different name or packaging: do you need separate filings

Whether one formula can share a single filing depends on what actually changes. A different Chinese product name is generally a different product in the eyes of consumers and usually needs its own filing, with its own name basis and label artwork. A change that is only the sales packaging of an already filed product—such as another net content, another pack colour, or added promotional artwork—may be handled as a packaging update rather than a new product, if it meets the dossier rules.

Published 11 November 2026 · Updated 11 November 2026

How to judge the difference

If the Chinese name, efficacy claims, intended users or method of use change, or if the formula is more than a permitted minor change, reassess whether you have a new product. Selling the same formula under another trademark or generic name should not automatically reuse the original filing number. Gift boxes that only combine already filed products, without contacting the contents and without expanding the claims, have some simplified packaging-image arrangements, but each inner product still needs its own registration or filing.

What to prepare

For a new name, prepare a separate name basis, label artwork and filing or registration file. For a packaging-only update, upload the new label images or the required remarks before the new pack is placed on the market, following the Provisions on Management of Cosmetics Registration and Filing Dossiers.

Cautions

If you are unsure whether you are “changing the name” or “changing the box,” compare both artworks and the formula side by side before printing. See also how to change a filed formula, label or product name.

Questions we are often asked

Can two shade names share one colour-cosmetics filing?

Shade identification is often part of the product name or of a series identification. Whether shades may share evidence depends on the current rules, including any provisions on similar formula systems. Do not assume that every colour in a range automatically shares one filing number.

Does a holiday sleeve require a new filing?

A sleeve that only adds promotional information to an already filed product is often a packaging update, not a new name. If it introduces a new Chinese product name or new claims, treat it as more than a sleeve.