Making Sense of China's Notorious National Drug Reimbursement List
What the recent publication of this high-stakes annual cycle revealed about how China prices risk, manages drug access and controls access to health innovation.
🔬This is a Real Diagnosis post at China Health Pulse, where we dive deeper into key topics and current trends.
Last month, I wrote about China’s health payer, the National Healthcare Security Administration, and why its control of the National Reimbursement Drug List (NRDL, 国家医保目录) gives it such extraordinary influence. The NRDL is the national catalogue that determines which medicines are covered by China’s public insurance system - and, in practice, which drugs can reach patients at scale.
This post looks more closely at the NRDL itself, and at what this year’s update reveals about how China’s reimbursement system now works.
The majority of Chinese patients (95–98%) are publicly insured, and so any company wanting to access the market at scale needs their drug on this list. Each year, from early summer through to December or January, foreign and domestic firms alike must model scenarios, engage stakeholders and negotiate intensively in an effort to persuade the state over price. The outcome is well known to be harsh. Discounts of 60–90% are common, and when the final decisions arrive - as they did this year on 7 December 2025 - they are definitive.
This system has been in place since 2018, when the NHSA was established, and the experience has not softened. Deliberations remain closed, and rationales remain unpublished. For outsiders, the system continues to feel compressed and difficult to read: an unforgiving black box with material commercial consequences.
What has changed is who is able to navigate that opaque progress. After eight annual cycles, patterns are now visible. Certain types of product continue to move through the system, while others still stall. Price expectations have become marginally easier to anticipate. Signals are accumulating even if rules remain unwritten.
Familiarity now matters. While inexperienced teams may continue to focus narrowly on headline discounts, and struggle when outcomes follow a logic they did not fully anticipate; others can now enter NRDL season with a clearer sense of where an asset sits, which pathway it is likely to require, and which constraints will matter most. No guarantees exist, of course, but uncertainty has become increasingly manageable.
This is visible in the numbers. Overall success rates remain historically low at around 37%, but negotiation success among drugs that reached the formal negotiation stage rose to approximately 88%, the highest level seen in recent cycles.
This year’s update combined two things at once:
Adjustment of the core reimbursement list, the gatekeeper which continues to prioritise therapies that can scale predictably through existing care pathways without destabilising budgets or delivery
The formal launch of a national Commercial Health Insurance Innovative Drug List (I first wrote about it here when it was announced last year), a new controlled-release valve, “Category C”, which is beginning to sort innovation by affordability profile and risk.
This post analyses:
This year’s NRDL cycle - numbers, categories, the perennial foreign vs domestic drug debate
“Category C” - the new Commercial List
“Unwritten Criteria” - what I see in terms of how inclusion decisions are shaped behind the scenes
Why listing does not equal access on the ground
Related:
This year’s NRDL
The numbers
This year’s NRDL was published on 7th December 2025, effective as of 1st January 2026. The competitive environment this year was among the tightest yet.
