Exporting Cosmetics to China: NMPA Filing, Registration and Labels

General or special: filing or registration

The CSAR sorts cosmetics by risk. Products for hair dyeing, perming, freckle removal and whitening, sun protection and hair-loss prevention, and products claiming a new efficacy (a claim not in NMPA's cosmetics classification catalogue), are special cosmetics; everything else is a general cosmetic (Article 16), and toothpaste is managed like one (Article 77).

Imported special cosmetics must be registered with NMPA before they are imported (Article 17). The registration certificate is valid for 5 years (Article 20), and imported special cosmetics carry a number beginning 国妆特进字. Imported general cosmetics are filed online with NMPA before import, and the filing is complete once the dossier has been submitted. Filers then send an annual report, between 1 January and 31 March, for each product filed at least a year earlier.

Both routes use the same core dossier (Article 19), with extra items for imports:

• Names and addresses of the registrant or filer and the manufacturer, and the product name
• Formula or full ingredient list, and the technical standard the product follows
• Label sample and test reports from a qualified testing institution
• Product safety assessment report
• Proof that the product is on sale in the registrant's or manufacturing country, issued by a government authority or an industry association; not needed for formulas designed for China, and since July 2026 a China-first launch statement can replace it
• Notarised authorisation of the domestic responsible person, and Chinese translations of all foreign-language documents

The domestic responsible person

An overseas registrant or filer must appoint an enterprise legal person in China to handle registration and filing, help monitor adverse reactions and carry out recalls (Article 23). The overseas company stays the registrant or filer; the domestic responsible person acts for it, and its name and address go on the Chinese label. It can be your importer, a subsidiary or a regulatory agent.

The authorisation letter must be notarised and name both parties, the scope and the term; submit a new one before it expires. Since NMPA Announcement 2026 No. 70, changing the domestic responsible person needs only a notarised authorisation, a list of the products concerned and a commitment to take on responsibility.

Safety assessment, animal testing and ingredients

Every product needs a safety assessment by the registrant or filer, itself or through a professional body (Article 21), following NMPA's 2021 Technical Guidelines for Cosmetic Safety Assessment. A simplified report was accepted until 1 May 2025; since then registrations and filings need the full version. Under NMPA Announcement 2024 No. 50, some lower-risk general cosmetics may submit only the basic conclusion and keep the full report on file, but higher-risk products such as children's and whitening cosmetics submit the full report.

Since 1 May 2021, a general cosmetic can be filed without toxicology test reports if its manufacturer holds a production quality management (GMP) certificate issued by a government authority in its country and the safety assessment fully confirms the product's safety (NMPA Announcement 2021 No. 32, Article 33). Every manufacturing site must hold such a certificate. The waiver does not apply to products claimed for infants and children or where the company is rated for key supervision.

NMPA Announcement 2026 No. 70, effective on publication in July 2026, extends the waiver, on the same conditions, to perming products, non-oxidative hair dyes, whitening products that act only by physical covering, and general cosmetics using new ingredients, except children's products. Other special cosmetics, such as sunscreens, oxidative hair dyes and anti-hair-loss products, still need toxicology test reports.

Ingredients should be on China's Inventory of Existing Cosmetic Ingredients and meet the Safety and Technical Standards for Cosmetics; an ingredient used in cosmetics in China for the first time is a new ingredient and must be registered or filed before use. Those with preservative, sunscreen, colourant, hair-dye or freckle-removing and whitening functions need NMPA registration, others are filed, and all are monitored for 3 years (CSAR Articles 11 and 14). New dossier rules for them (Announcement 2026 No. 59) apply from 15 July 2026. Since No. 70, filers no longer enter ingredient safety information files or submission codes, only the ingredient manufacturer's name, and keep the supporting data on file.

Efficacy claims

Claims need a sufficient scientific basis, and the registrant or filer publishes a summary of the supporting literature, data or test results on NMPA's designated website (Article 22). Under NMPA's Norms for Cosmetic Efficacy Claim Evaluation, in force since 1 May 2021, claims of freckle removal and whitening, sun protection, anti-hair-loss, anti-acne, nourishing and repair need human efficacy tests. Products whose effects can be seen or smelt directly, or come from simple physical covering, adhesion or friction, need no efficacy evaluation.

Announcement 2026 No. 70 lets other claims be supported by industry standards, international standards or validated in-house methods, and lets products with similar formulas share test data. Labels may not claim medical effects.

Chinese labels

The Cosmetics Labeling Management Measures (NMPA Announcement 2021 No. 77) apply to products registered or filed since 1 May 2022; older products had to update their labels by 1 May 2023. An imported product may carry a Chinese label printed on the pack or a Chinese sticker, but a sticker must match the content of the original label (CSAR Article 35). Foreign text, apart from trademarks, may not be larger than the Chinese.

Packs of 15 g or 15 mL or less need only the key items (name, registration number, registrant, net content, shelf life) on the visible panel; the rest may go in an insert. Medical terms, false or unverifiable claims and invented concepts are banned. Since 1 February 2026 NMPA has run a three-year electronic label pilot in Beijing, Shanghai, Zhejiang, Shandong, Guangdong and Chongqing for selected companies, combining a QR code with the physical label.

• Chinese product name, and for special cosmetics the registration number, on the visible panel
• Name and address of the registrant or filer and of the domestic responsible person
• Name and address of the manufacturer
• Number of the technical standard the product follows
• Full ingredients under their standard Chinese names, in descending order
• Net content, and either production date and shelf life or batch number and expiry date
• Directions for use and any required safety warnings

Customs clearance and cross-border e-commerce

Customs inspects imported cosmetics, and goods that fail may not be imported; the importer must check before import that each product is registered or filed and meets Chinese rules and mandatory standards (CSAR Article 45). Until 30 November 2026 the 2011 inspection rules (AQSIQ Decree 143, as amended) apply: the importer (consignee) is filed with customs and declares with the registration or filing proof, a first import also needs a Chinese label sample with the original label and a translation, and the goods stay in a place customs designates or approves until they pass. Failures on safety, health or environmental items mean destruction or return; other failures may be corrected under customs supervision.

GACC Decree 284 replaces those rules from 1 December 2026. It ends the filing of consignees, has customs check registration and filing data electronically, moves inspection from the port to the destination the importer declares and keeps label checks. Samples for registration, testing, R&D or promotion are exempt from inspection in reasonable quantities with a non-sale undertaking. Cosmetics fall mainly under HS headings 3303 to 3307; Triplicate's HS code lookup and invoice generator help keep product names and codes consistent on the shipping documents.

Cross-border e-commerce (CBEC) retail imports, shipped directly to the buyer or from a bonded warehouse (customs code 1210), are supervised as personal-use items and are not subject to first-import licensing, registration or filing (GACC Announcement 2018 No. 194). Products must be on China's CBEC positive list, a consumer may spend up to RMB 5,000 per order and RMB 26,000 per year, and buyers must be warned that goods may lack Chinese labels and may differ from Chinese standards. Buyers may not resell them, and the overseas seller registers with customs through a domestic agent. Selling to a Chinese importer in ordinary trade needs the full NMPA, labelling and customs rules.

Rules change. Confirm current requirements with NMPA, your domestic responsible person and a licensed customs broker before shipping.