What does an imported cosmetic need before it can be sold in China? (进口化妆品备案)

Imported cosmetics sold in China through ordinary trade must be filed with the National Medical Products Administration (NMPA) before import, or registered first if they are sunscreens, hair dyes, whitening or similar products. A Chinese company the brand appoints files for it. Cross-border e-commerce sales need neither, and since 28 July 2026 fewer products need animal-test data.

A distributor in Shanghai wants to order your skincare range, and its first question is whether the products have filing numbers. If they do not, nothing ships: the importer must check that every product has been registered or filed before importing it, and may not import one that has not.^⁠[1] From 1 December 2026 the filing number, or a special cosmetic’s registration certificate number, must also go on the customs declaration, and customs checks it by automatic comparison with the regulator’s electronic records.^⁠[5,6] A product imported without a filing can be confiscated, with a fine of up to ten times its value.^⁠[1]

Registering or filing a product needs a Chinese company to act for you, called the domestic responsible person (境内责任人). Since 28 July 2026 you can replace that company without its consent.^⁠[3] That matters most when your distributor holds the role.

Is my product a “special” or a “general” cosmetic?

It is special if it dyes or perms hair, removes spots or whitens, protects from the sun, prevents hair loss, or claims an effect China has not recognised before. Everything else is general.^⁠[1] The class decides the procedure, the time and the test data.

	Special cosmetics	General cosmetics
Examples	Sunscreen, hair dye, perm, whitening and spot-removing, anti-hair-loss, a new efficacy claim	Moisturiser, cleanser, make-up, shampoo, perfume, toothpaste
Procedure注册 / 备案	Registration: a certificate from the NMPA before import	Filing: done online before import
When it is done	When the certificate issues, after review	When the file is submitted
How long it lasts	5 years, renewed at least 30 working days before expiry	Until withdrawn; production and imports reported each year

Toothpaste is treated as a general cosmetic. Soap is outside the cosmetics rules unless it claims a special effect, such as whitening.^⁠[1]

Who can be our domestic responsible person, and what does it answer for?

Any company incorporated in China can hold the role: your own subsidiary, your distributor, or a firm that does it as a service.^⁠[1] It files in your name, helps with adverse-reaction monitoring and recalls, and cooperates with inspections. It also carries the quality and safety responsibility for products on the Chinese market that your agreement with it gives it.^⁠[2]

The obligations fall on both sides. A responsible person that fails to help with monitoring or a recall can be fined RMB 20,000 to 100,000, or up to RMB 500,000 in a serious case. A foreign brand that refuses to carry out a penalty decision can be barred from importing cosmetics into China for 10 years.^⁠[1]

Until July 2026, moving the role to a new company meant producing the old one’s stamped consent, or a court judgment. Now the new responsible person files a notarised authorisation letter, the list of products and its undertaking to take on the old one’s responsibilities.^⁠[3] Who holds the role is still worth settling in the distribution agreement, with the other points in appointing a Chinese distributor or agent.

How long does a filing or a registration take?

A general cosmetic’s filing is complete the day it is submitted, and the regulator publishes it within 5 working days.^⁠[1,2] A special cosmetic waits for review: up to 90 working days of technical review, 20 for the NMPA’s decision and 10 to issue the certificate.^⁠[2] If the reviewers ask for more material, you have 90 working days to supply it, and the review clock starts again.

Take a Danish skincare brand with a face cream and an SPF 30 day cream, appointing its Shanghai distributor as responsible person in November 2026. The face cream can be filed as soon as its documents are ready, and imported once filed. Because the day cream is a sunscreen, it needs a certificate. Review stages alone allow 120 working days, roughly six months, before any request for more material. A launch that pairs the two products should be planned around the day cream.

Does China still require animal testing for imported cosmetics?

Not for most general cosmetics, and since July 2026 not for some special ones. A general cosmetic can be filed without its toxicology report if two conditions hold. The plant must hold a quality-management certificate issued by its own country’s government authority, and the product’s safety assessment must fully confirm its safety.^⁠[4] Products claimed for babies and children do not qualify. Nor do products using a new ingredient still under safety monitoring, or a brand, responsible person or plant graded for priority supervision.

Announcement No. 70 of 28 July 2026, which the NMPA headed as reducing animal-test data, extends the same waiver on the same conditions. It now covers perms, non-oxidative hair dyes, whitening products that work only by covering the skin, and general cosmetics using a new ingredient, children’s products excepted.^⁠[3] Sunscreens, oxidative hair dyes, anti-hair-loss products and the other special cosmetics not on that list still need the report.

The condition to check first is the certificate. The general proof of good manufacturing practice in the filing documents may come from a certification body, but the waiver names a certificate issued by the government authority where the plant is.^⁠[4] For a brand that also sells in the EU, the stakes run the other way as well. The EU Court of Justice held in 2016 that the EU ban can stop a product being sold in the EU if animal-test data produced for another market is used to prove its safety there.^⁠[7]

What documents does the file need from us?

Four things come from abroad, beyond the formula and test reports:

1. Proof the product is on sale in the brand’s country or the country of manufacture. Since 28 July 2026 a product launched in China first, or at the same time as elsewhere, can give a first-launch declaration instead.^⁠[1,3]
2. Proof the plant meets good manufacturing practice, issued or recognised where the plant is.^⁠[1]
3. The authorisation letter appointing the responsible person, stating both names, the scope and the period of the authorisation.^⁠[4] A change of responsible person needs it notarised.^⁠[3]
4. Chinese translations of everything in another language, with the original attached.^⁠[4]

Where an original cannot be supplied, the rules on filing documents accept a copy notarised in China or confirmed by a Chinese embassy or consulate.^⁠[4] Document notarisation and apostille covers the notarised authorisation, and certified Chinese translation the last item. The Chinese label can be printed on the pack or stuck over the original, but a sticker must say what the original says.^⁠[1]

Can we sell cosmetics to Chinese consumers without any filing?

Yes, through cross-border e-commerce retail import. Goods sold that way are treated as the shopper’s personal-use items, so registration and filing requirements do not apply.^⁠[8] The limit is the buyer. A consumer may not resell what they bought, so the route cannot supply a distributor, a salon or a shop.^⁠[8]

How the bonded-warehouse version works, with its per-order and annual limits, is in what 1210 bonded import is.

Market Entry and Structure Advisory sets out which route, which products first, and who should hold the responsible person role before the first order is placed.

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