China NMPA CBD Cosmetics Ban 2025 Compliance: A Crucial Update for US Brands
China’s booming cosmetics market has long attracted international attention. However, as of 2025, the China National Medical Products Administration (NMPA) continues to enforce a strict ban on cannabidiol (CBD) and all cannabis-derived ingredients in cosmetics. For global and US beauty brands eyeing growth in China, this reality demands unparalleled vigilance in compliance, especially as Chinese authorities tighten standards, update ingredient testing protocols, and reinforce advertising restrictions.
Latest NMPA Regulatory Activity in 2025
2025 has seen the NMPA institute several key regulatory changes and reinforced its position barring CBD from cosmetics:
- Ingredient Management: In June 2025, the NMPA reinforced the strict management of cosmetic ingredients with the latest Regulations on the Supervision and Administration of Cosmetics (CIRS-Group, June 2025). CBD, hemp seed oil, cannabinol, and related compounds remain strictly prohibited.
- Testing Standards: May and June brought updates to testing methods, including expanded ingredient screening and enhanced risk management—further diminishing covert market access for banned actives like CBD (ZMUni, 2025).
- Advertising Oversight: Municipalities like Beijing issued fresh guidelines for cosmetic advertisement compliance, clamping down on misleading or exaggerated product claims and tightly scrutinizing any suggestion of therapeutic effects—a frequent pitfall for brands marketing CBD beauty.
The Continued Ban on CBD and Cannabis-Derived Ingredients
Since May 2021, the NMPA has blacklisted key cannabis-related ingredients for use in cosmetics, including:
- Cannabidiol (CBD)
- Cannabis sativa fruit/seed oil
- Cannabis sativa leaf extract
- Cannabinol (CBN) and any hemp extract
Despite some industry rumors of a shift, these prohibitions remain firm in 2025. Brands cannot import, produce, or sell any cosmetic product containing these ingredients in China, and there have been no public movements toward lifting this ban.
Why the Ban?
The NMPA's rationale is twofold:
- Consumer Safety: There is ongoing regulatory concern regarding the potential psychoactivity or unclear safety profile of CBD and related cannabinoids.
- Alignment with National Drug Policy: China maintains a conservative approach to all cannabis compounds—even non-psychoactive ones—from a social policy and drug enforcement perspective.
Cross‑Border E‑Commerce: Shrinking Options & Rising Customs Risk
While the outright use of CBD in domestic manufacturing and traditional import channels is banned, some Western brands have attempted to access Chinese consumers through cross‑border e‑commerce (CBEC). These transactions—often facilitated by platforms such as Tmall Global or JD Worldwide—have previously benefited from regulatory grey zones. But as of 2025, China Customs authorities have increased scrutiny and enforcement against products with banned ingredients, including those arriving via cross-border “personal use” channels.
Customs Scrutiny and Seizure Risk
- Random Inspections: Shipments may be stopped, opened, and tested for banned components. Declarations, product labels, and even external marketing content are reviewed.
- Ingredient and HS Code Declarations: Companies must ensure all ingredient lists (using China-specific INCI naming) conform to NMPA requirements, and HS codes must not disguise the true content of banned cannabinoids.
- Direct Liability: Brands can face product seizure, fines, or even blacklisting from Chinese e‑commerce channels if their goods are found non-compliant.
Case Example:
Several non-compliant cosmetics—including those merely suggesting cannabis-derived benefits—have been publicly listed and removed by Chinese authorities, underscoring enforcement risk (CISEMA, 2025).
Marketing and Advertising: New Restrictions
2025 guidelines published by the Beijing Municipal Administration for Market Regulation further reinforce restrictions on cosmetic advertising claims. No claims of therapeutic, anti-anxiety, or anti-inflammatory effects (often associated with CBD) are permitted. Local authorities are targeting not only ingredient lists, but also:
- Marketing language—both online and offline
- Product imagery or design elements suggesting cannabis origin
- Implied claims referencing Western cannabis culture or wellness paradigms
This makes it essential for cross-border marketers to completely scrub campaigns, e-commerce shops, and influencer scripts of any reference or allusion to banned compounds.
What Should US Brands and Exporters Know?
1. Product Ingredient Review: Zero Tolerance
- Do not attempt to import, sell, or market any cosmetic containing CBD, CBN, hemp seed oil, or related extracts—no threshold limits or testing tolerance exist. Even trace amounts may trigger compliance action.
- Regularly review formulas and supply chain records, including batches produced for other international markets, to ensure accidental inclusion is prevented.
2. China-Specific INCI and Compliance Paperwork
- Review all ingredient lists with a China-based regulatory consultant. China-required INCI names and safety assessments are strictly audited.
- Maintain dual documentation: one for the global market, another for China, clearly excluding all banned substances.
- Review and correctly code HS (Harmonized System) tariff numbers—avoid any customs misrepresentation.
3. Scrub Advertising and Marketing
- Carefully review product names, website copy, key visuals, KOL/influencer scripts, and even social hashtags for any reference to hemp, CBD, or related wellness messaging.
- Avoid indirect or implied claims—regulators increasingly penalize "functional cosmetics" promising results outside the permitted cosmetic scope.
- Comply with municipal ad guidelines, which may have even stricter requirements than national law in large cities like Beijing and Shanghai.
4. Staff and Agency Training
All China-facing stakeholders—including e‑commerce partners, influencers, logistics staff, and customer service—must know the updated prohibitions. Mistakes in labeling, shipping, or communication can now result in immediate product seizure.
- For brands serious about the APAC (Asia-Pacific) region, consider region-specific product lines completely free of cannabis-derived ingredients.
- Focus on alternative actives (such as Cica, niacinamide, or rare botanicals) that meet both Chinese regulatory and consumer trend requirements.
Enforcement Trends: More Stringent, More Digital
2025 marks an era of aggressive enforcement through digital monitoring and expanded lab testing. Authorities are:
- Routinely testing imported and CBEC products for banned ingredients.
- Publicizing enforcement actions, including non-compliant product blacklistings and public advisories (ChinaCosIng News, 2025).
- Rolling out new ingredient and batch-level safety documentation requirements starting in mid-2025, escalating paperwork and review obligations.
Key Timeline: What’s Changing in 2025–2026?
- March–June 2025: New and revised testing standards announced.
- August 2025: Stricter oversight and enforcement of new safety measures (RRMA Global, 2025).
- March 2026: Official implementation of updated testing protocols by NMPA.
Practical Steps: US Brand Checklist for 2025 and Beyond
- Conduct China-specific INCI ingredient audits for every product, every quarter.
- Exclude all cannabis-derived ingredients from any product intended for the Chinese market, regardless of sales channel.
- Review and align all e‑commerce, ingredient disclosure, and HS code declaration documentation with local regulation.
- Scrub all advertising, brand assets, and influencer content for direct or indirect CBD or cannabis references.
- Monitor developments from official NMPA and local municipal authorities, as city-level rules may tighten faster than national law.
Bottom Line: Navigate the China NMPA CBD Cosmetics Ban for Real Compliance
For US and global beauty brands, China’s stance on CBD in cosmetics is non-negotiable in 2025. Attempting to skirt the ban—not just in ingredient use, but also in labeling and advertising—invites rapid enforcement, product seizure, financial loss, and long-term brand risk. The market opportunity is vast, but so are the pitfalls for non-compliance.
Stay continuously updated—partner with compliance specialists and regulatory intelligence platforms like CannabisRegulations.ai to ensure your business is always China NMPA–ready.
Informational purposes only: This article does not constitute legal or regulatory advice. For comprehensive support tailored to your brand, consult qualified experts and leverage real-time resources on CannabisRegulations.ai.