Original source
Guidance / Q&A
化妆品企业生产质量管理体系提升三年行动计划（2026—2028年）
- Official date
- 2025-12-12
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Official source. NMPA GMP improvement action plan 2026–2028
Key points
- Three-year provincial action, not a replacement of the manufacturing licence rule.
- Focus on completeness of quality-system documents and consistency with registered/filed process.
- Brands should expect questions at the contract manufacturer, not only at the RP office.
Dates. Issued 12 December 2025; action window 2026–2028.
Verify in the official text. What provincial bureaus will actually inspect in 2026 vs later years.
Open questions. Confirm any transitional stock rules and whether your exact INCI / product type is named. This desk brief is a prioritisation aid, not a legal determination.
What changed: A 2026–2028 quality-system campaign for China cosmetics manufacturers.
Who is affected: China plants and brands using them.
Suggested next steps: Commission a file-vs-floor review at the manufacturing site.
On 12 December 2025 NMPA issued a 2026–2028 action plan for lifting cosmetics manufacturers’ quality systems.
China factory owners and brands whose contract manufacturer sits in China should care.
Risk is medium: more inspections against the file you already registered, not a surprise ISO swap.
This quarter: ask the plant for a gap review of SOP vs registration/filing process description.
Official text
English translation — the official-language text prevails
Unofficial English translation of the NMPA three-year action plan issued 12 December 2025. The Chinese official text prevails.
Drug regulators are instructed to take a problem-oriented and goal-oriented approach and to survey quality-system construction and operation of cosmetics enterprises in their administrative regions, focusing on:
- completeness of quality-system documents;
- consistency between the production process and the registered/filed process.
The plan covers 2026–2028. It is a supervisory campaign, not a replacement of the manufacturing-licence statute. Brands using China contract manufacturers should expect deeper file-versus-floor questions during the window.