Cosmetics that wish to be marketed in China need to complete cosmetic registration or filing through National Medical Products Administration or Local Drug Administration, only after which they can come into Chinese market and be sold in China. Cosmetic registration applicants and filers need to be responsible for the quality, safety and effectiveness of cosmetics. Overseas applicants need to submit application and filing information through enterprise legal persons in China.
Cosmetics are divided into special cosmetics and ordinary cosmetics in China. You can get an initial idea of Chinese regulatory requirements through the comparative information below.
Cosmetics Monitoring Model
| Special Cosmetics | Ordinary Cosmetics | |
| Review and Approval Mode | Registration | Filing |
| Declaration Subject |
|
|
| Review And Approval Authority | National Medical Products Administration (domestic/imported) |
|
| After Market Launching | Renewal of registration (Every 5 years) | Submit report annually |
| Product Examples | Hair dye, perm, blemish spots remover, brightener, sunscreen (ultraviolet rays), anti-hair loss agent, cosmetics that advertise new effects. | Cosmetics other than special cosmetics, including general skin/hair care, body care, nail care, depilation, deodorant, perfume, make-up, and other products. |
Cosmetics Consulting Service
NMPA has very strict approval processes and requirements for both ordinary and special cosmetics. Especially after the introduction of new regulation and policy in 2021, the management of cosmetics is more standardized. HMK can provide you with customized solutions, for example, we can help you determine whether your product is classified as “special” or “ordinary”, confirm whether the formula and packaging meet the relevant requirements of China. For more information about the NMPA application and registration process (including timetables) in China, please contact us.
|
Services |
| Provide pre-review and adjustment suggestions on formula and packaging |
| Assist in preparing inspection materials |
| Assist in delivering samples for import, export, and domestic transportation; and following up the whole testing process |
| Prepare and submit technical documents and application materials |
| Follow up technical review until obtaining the certificate |
| Provide help in regulatory affairs, such as change application, renewal, and change of legal agent after product launch. Provide regulatory support after the listing approval as your legal agent in China. |
Contact Us
If you or your business is experiencing the following problems, please contact us:
- You are a manufacturing company and want to sell your products to China.
- Your cosmetics, nutritional supplements and health foods are being sold in China through cross-border e-commerce platforms, but you still want to come into Chinese market through general trade.
- You are not sure whether the raw materials or ingredients of the product meet Chinese standards.
- You are not sure if the packaging information of the product complies with Chinese standards.
- You are looking for a responsible agent in China.
- You do not know how your product should be tested in China.
- You want to know the latest regulations, standards, policies and other information or news in China.
- You want to know whether there are similar products in Chinese market, and the sales and consumer feedback of your competing products.
NMPA Filing and Registration Process of Import Cosmetics
Q&A About Cosmetics Filing and Registration
- What is a cosmetic label?
According to Article 3 of the “Measures for the Administration of Cosmetics Labels”, cosmetics labels refer to the characters, symbols, numbers, patterns and other marks on the product sales packaging used to identify and explain the basic information, attribute characteristics and safety warnings of the product, as well as packaging containers, packaging boxes and instructions with identifying information. In other words, the label includes both “software” information and “hardware” information carriers.
- Can the cosmetics label be marked with words such as “researched by XXX hospital”?
According to Article 19 of the “Measures for the Administration of Cosmetics Labels”, cosmetics labels are prohibited from using the name or image of state organs, public institutions, medical institutions, public welfare institutions and other institutions and their staff or appointed experts to prove or recommend.
The words “researched by XXX hospital” in the label are suspected of using medical institutions as proof or recommendation, which does not meet the relevant requirements.
- If the product is cancelled due to a change in the formula, can the product produced before the cancellation be sold until the end of the validity period? If the product is cancelled due to formula change, can the previous product name be retained when re-filing?
Since the date of cancellation of the product, the enterprise shall not reproduce this product. The products lawfully produced by the enterprise before the cancellation of the products may be sold until the expiration date of the products.
If the product is cancelled due to the change of the original formula, the same product name can be used for the filing, and it is recommended to mark the “new formula” or “upgraded formula” in its new label.
