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Guide
Types of efficacy evaluation in China, and when each is used
Efficacy claim evaluation in China follows the Efficacy Claim Evaluation Standard. The usual evaluation types are human efficacy tests, consumer-use tests, laboratory tests, and literature or research-data analysis. You cannot choose any method for any claim. The annex to the standard states which methods may be used for each listed efficacy. For example, moisturizing may be supported by a human test, a consumer-use test, a laboratory test or literature; soothing generally needs a human test, a consumer-use test or a laboratory test and cannot rest on literature alone; repairing should be supported by a human efficacy test.
How to match the claim to a method
Read the exact Chinese wording of the claim against the annex, not against a marketing translation. “Repairing the barrier” and “moisturizing” are different requirements. Claims that work only by physical covering, such as making spots less visible by covering them, have their own arrangement and should not be mixed with whitening human studies. Sunscreen, whitening or spot-removal and anti-hair-loss claims also have to meet special-cosmetics testing and evaluation requirements.
What to prepare after the study
When evaluation is completed, an abstract of the efficacy-claim basis should be uploaded for public query, as the standard requires. Literature or laboratory data can replace a human test only when the annex allows that substitution for the specific claim.
Cautions
Announcement No. 70 of 2026 broadened the test methods that may be accepted for efficacies other than whitening, sun protection and anti-hair-loss, where there is sufficient scientific justification. It also describes sharing efficacy data among similar formula systems in defined cases. Apply those provisions as written. Jinshang coordinates efficacy work with partner laboratories; the evaluating institution issues the report.
Questions we are often asked
Can one consumer-use test cover every claim on the pack?
Only if each claim is of a type that the standard allows to be supported by a consumer-use test. Repairing claims, for example, should have a human efficacy test.
Do we have to publish the full report?
The standard requires an abstract of the evaluation basis to be made available for public query. Keep the underlying report available as required.
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.
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