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Guide
Do different lipstick shades need separate China filings?
Different lipstick shades generally need to be identified as separate products in China when their colorant formulas differ. You should not sell a shade that has no corresponding filing or registration record. Announcement No. 70 of 2026 allows the same filer or registrant, for the same brand, to choose a representative product and share specified microbial, physical-chemical, toxicology, human-safety or efficacy data with other similar-formula products that differ only in colorants and a short list of other ingredients, after the required explanations. That is a way to reduce repeated testing, not a way to leave shades off the system.
How to judge the path
If two lipsticks differ only in shade colorants and otherwise meet the announcement’s similar-formula definition, you may be able to share data. If they also differ in active skincare systems, SPF or names in a way the announcement does not cover, treat them separately.
A new Chinese name usually needs its own file even when the formula is the same. See same formula, different name or packaging.
Typical documents, tests and labels
Keep shade names on listings consistent with the official file. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform. After a record is issued, check it on the official NMPA filing query https://hzpba.nmpa.gov.cn/gccx/ and the NMPA data-search page https://datasearch.nmpa.gov.cn/datasearch/home-index.html#category=hzp.
Cautions
Do not apply the about 10–20 day ordinary-filing cycle to an SPF lipstick; that product must be registered as a sunscreen.
Questions we are often asked
What if I launch 20 more shades next season?
Handle them as additional products and use the similar-formula data-sharing conditions if they still apply. Do not ship them for general-trade sale before the records exist.
Does a magnetic matching lipliner count as the same shade filing?
Not if it is a separately used product with its own formula, even when the shade name matches the lipstick.
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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