Three types of transitional labeling for cosmetics semi-finished packaging: When will the inventory of old labels finally be depleted?

Last October, the owner of a cosmetics contract manufacturing company with 15 years of experience called me. There were still 180,000 sets of old packaging in the warehouse. The labels still displayed “Domestic Cosmetics Special Approval,” but the new measures required dual labeling as “Domestic Cosmetics Special Approval + Filing Number.” He asked me: When exactly can this inventory be used up? Can the printing factory continue production?

This is the same trap that nearly every cosmetics brand has fallen into since the new Administrative Measures for Cosmetics Labeling took effect on May 1, 2022. The new measures provided a 24-month transition period, with full mandatory enforcement beginning on May 1, 2024. However, at the beginning of 2026, I found that at least 30% of cosmetics brands still had old-version packaging materials in stock—especially among some long-established brands and brands formed through mergers and acquisitions, where it was very common to find two versions of the same packaging coexisting in warehouses.

Category 1: The “Work-in-Progress” Boundary of Legacy Label Inventory

Semi-finished packaging is the most distinctive concept in the cosmetics industry. It is neither finished product packaging (which has already been filled with its contents) nor raw materials (which have not yet gone through the printing press), but rather an intermediate state—printed, die-cut, and formed, and ready to be filled.

The printing factory owners’ biggest concern is just one question: Do existing label inventories count as “work in progress”? Can they still be used?

There are two criteria for actual implementation. The first is "based on the printing date"—as long as the packaging material was printed before May 1, 2022, even if the finished product is not launched for sale until after 2024, it is considered "produced inventory" and may remain in circulation. The second is "based on the filling date"—if a semi-finished product is filled into a finished product only after May 1, 2024, it must be relabeled with a new label.

The first interpretation reflects the actual practices of most provincial drug regulatory authorities, while the second is stricter but more difficult to implement. When accepting such “use the old version” orders, the safest approach for the printing plant is to have the brand owner issue a certificate of printing date (issued by the printing plant itself and indicating the production batch number) as evidence of exemption liability if the product is subsequently selected for inspection.

Type II: Temporary "dual-labeling" solution during the transition period

During the two-year transition period from May 2022 to May 2024, the National Medical Products Administration allowed the old and new versions to coexist—meaning that the old version of the packaging materials was not required to be replaced immediately. However, to ensure compliance, many brand owners opted to "patch" their packaging materials:

All three options can be produced by the printing plant, but they share one prerequisite: the blank space on the old label must be sufficient. If the original label was designed to print right to the edge without leaving room for the filing number, the entire label will have to be reprinted, as there is no way to remedy this.

I have seen the most extreme case: a domestic skincare brand cleared its inventory in 2023 by affixing "adhesive labels" to 80,000 sets of old serum packaging. This added 0.18 yuan per set, totaling 14,400 yuan—more expensive than reprinting the entire version. But there was no alternative, as the old version was designed in 2021 and had no reserved space for the filing number.

Category 3: Where Does the Printer’s Responsibility End?

Printing plant owners often ask me: When customers bring me old-version label inventory, can I actually take the job? And if I do, could I be held liable if the drug administration authorities investigate?

This question should be divided into two levels.

The first layer is printing compliance——the printing factory is responsible only for ensuring that the “printed content complies with the regulations in effect at the time.” Packaging materials printed before May 2022 are compliant under the regulations then in effect, and the printing factory bears no retroactive liability.The second layer is product compliance——after cosmetics are placed on the market, responsibility for ensuring that the filing number, ingredients, warning statements, and other elements comply with current regulations lies with the brand and the filing party, not the printing factory.

Therefore, in practice, the printing plant only needs to do one thing: add a line to the order contract stating, "The printing date of the packaging materials for this batch is XXXX Year XX Month XX Day, in compliance with the regulations and requirements effective at that time." With this line included, the printing plant's responsibilities are clearly defined.

However, there is one exception to be aware of—if the printing plant knows that the customer intends to use the old packaging on finished products after May 1, 2024, yet continues to produce according to the old version, this constitutes “assisting a violation.” In such cases, the printing plant bears joint liability. Although there are few actual cases of accountability, the risk does exist.

3 Practical Recommendations from Actual Printing Plant Experience

First, do not completely reject orders for old-version packaging. Cosmetics brands are under considerable inventory pressure, and if printers turn down all such orders, they risk losing these customers. The key is to have the customer provide proof of the printing date while also retaining proper production records.

Second, the transition-period option prioritizes “patching” rather than “reprinting”. The cost of patching is 30%-50% of the cost of reprinting, while the lead time is reduced from 15 days to 5 days. However, this requires the old version to have reserved space.

Third, the wave of new orders at the beginning of 2026 mandates dual labeling—do not count on being lucky. Regulatory requirements for newly registered cosmetics are becoming increasingly stringent. The registration number, PAO symbol, and allergen warning are the three most frequently inspected items; missing any one of them means the product is noncompliant.

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