3 Types of Transition Period Labeling for Cosmetic Semi-Finished Packaging: When Will Your Old Label Inventory Be Cleared

Last October, a factory owner who has been doing cosmetic OEM for 15 years called me. He still had 180,000 sets of old-version packaging sitting in his warehouse—the labels still showed the four characters "国妆特字," but the new regulations require dual labeling of "国妆特字 + filing number." He asked me: when exactly can this batch be used up? Can the printer keep producing it?

This is the same pitfall almost every cosmetic brand has stepped into since the new Cosmetic Label Management Measures took effect on May 1, 2022. The new rules provided a 24-month transition period, with full enforcement beginning May 1, 2024. But at the start of 2026, I've found that at least 30% of cosmetic brands still hold old-version packaging—especially after mergers and acquisitions between established legacy brands and new brands, where it's very common to see two versions coexisting in the warehouse.

Type 1: The "Semi-Finished" Boundary of Old Label Inventory

Semi-finished packaging is the most unique concept in the cosmetics industry. It is neither a finished product (already filled with content) nor a raw material (not yet on the printing press), but rather an intermediate state—packaging that has already been printed, die-cut, and is awaiting filling.

The question printer owners care about most is this one: Does old-version label inventory count as "semi-finished"? Can it still be used?

In practice, there are two enforcement standards. The first is "based on printing date"—as long as the packaging was printed before May 1, 2022, even if the finished product is sold after 2024, it counts as "existing inventory" and can continue to circulate. The second is "based on filling date"—if the semi-finished product is filled into a finished product after May 1, 2024, the label must be replaced with the new version.

The first standard is what most provincial drug administration bureaus actually follow; the second is stricter but harder to enforce. When printers accept these "use old version" orders, the safest approach is to have the brand provide a printing date certificate (issued by the printer itself, noting the production batch number) as documentation of exemption if subject to spot inspection.

Type 2: Temporary "Dual Labeling" Solutions During the Transition Period

During the two-year transition period from May 2022 to May 2024, the National Medical Products Administration (NMPA) allowed old and new versions to coexist—that is, old-version packaging was not required to be immediately replaced. But for compliance reasons, many brand owners choose "patching" methods:

• Adhesive label overlay—sticking a new label over the old one, covering key fields
• Local UV printing—using UV printing to add the "filing number" characters onto blank space on the old version
• Inner packaging card insert—keeping the outer packaging unchanged while inserting a complete new label card inside the box

Printers can handle all three approaches, but they share a common prerequisite: the old-version label must have enough blank space. If the old version was originally printed edge-to-edge with no space reserved for the filing number, the entire version must be reprinted with no way to patch it.

The most extreme case I've seen: a domestic skincare brand clearing inventory in 2023 converted 80,000 sets of old-version serum packaging to "adhesive label overlay," adding RMB 0.18 per set—RMB 14,400 for 80,000 sets—more expensive than reprinting the whole version. But there was no choice, because the old version was designed in 2021 with no space reserved for the filing number.

Type 3: Where Does the Printer's Liability Boundary Lie?

Printer owners often ask me: a client brings me old-version label inventory—can I accept it? If the drug administration bureau catches them after I accept, am I liable?

This question needs to be broken into two layers.

The first layer is printing compliance—the printer is only responsible for whether "the printed content complies with regulations in effect at that time." Old-version packaging printed before May 2022 was compliant under the regulations then in force, and the printer bears no retroactive liability. The second layer is product compliance—after the cosmetic product is launched, whether the filing number, ingredients, and warnings comply with current regulations is the responsibility of the brand owner and the filing party, not the printer.

So in practice, there's only one thing printers need to do: add a line in the order contract stating "the printing date of this batch of packaging is XX/XX/XXXX, compliant with regulations in effect at that time." With this line, the printer's liability is clearly defined.

But there's one exception to watch out for—if the printer knowingly produces old-version packaging for a client who intends to use it on finished products launched after May 1, 2024, this constitutes "aiding a violation." In such cases the printer bears joint liability. Although actual enforcement cases are rare, the risk exists.

3 Practical Recommendations for Printers

First, don't completely refuse old-version packaging orders. Cosmetic brands face enormous inventory pressure, and if printers categorically refuse, they will lose these clients. The key is to require the client to provide a printing date certificate, and the printer should also keep its own production records.

Second, during the transition period, prioritize "patching" over "reprinting". Patching costs 30%–50% of reprinting, and the cycle shrinks from 15 days to 5 days. But the prerequisite is that the old version has reserved blank space.

Third, for the new wave of orders at the start of 2026, mandate dual labeling—don't take chances. Regulation of newly filed cosmetics is becoming stricter, and the filing number, PAO symbol, and allergen warnings are the three most frequently inspected items; missing any one means non-compliance.

Further Reading

• 3 Labeling Details Most Likely to Trip You Up Under the New Cosmetic Label Management Measures
• 4 Types of Cosmetic Label Standards: Ingredients / Shelf Life / Batch Number / Usage Instructions
• 3 Regulatory Requirements for Printing Cosmetic Filing Numbers on Packaging