Cosmetics registration in China
Cosmetics registration in China – an overview of requirements and processes
Since the new cosmetics regulation came into force (May 2021), companies wishing to sell cosmetic products on the Chinese market must meet numerous new requirements.
What counts as a cosmetic?
Under Chinese law, cosmetics are chemically manufactured products for daily use that are applied to the skin, hair, lips, nails, or other body surfaces for cleansing, care, protection, or beautification.
Classification: General vs. special cosmetic products
For registration purposes, a distinction is made between general cosmetics and specific cosmetics:
- General cosmetics: Skin, hair, and nail care, makeup, perfumes – only require registration before market launch (filing).
- Special cosmetics: Products with active ingredients such as whitening, sun protection, anti-hair loss, hair coloring, perming, or anti-pigmentation – require official approval before market launch (registration).
For products such as depilatories, deodorants, bust care, slimming products, or hair growth products, a transition period applies until the end of 2025.
Cosmetics registration process in China
Step 1: Authorized representative and account opening
Foreign companies must appoint a responsible person based in China to carry out the registration. The account is then opened on the registration portal of the NMPA (National Medical Products Administration):
👉 https://zwfw.nmpa.gov.cn/web/index
Step 2: Preparation of documents
The following information is required:
- Product details: name, formulation, application, effect, target group, body area
- Labeling, dosage, samples
- Manufacturer and supplier information, quality management system, possibly licensed manufacturers
- Information on adverse reactions & proof of an evaluation system
- GMP/ISO/QMS certificates
- Safety assessments, formulations with percentages, manufacturing processes
- Raw material specifications, MSDS for critical ingredients
- Certificate for free sale
Processing time: approx. 30 days
Step 3: Review by the authorities
After submission of the documents, the dossier is reviewed by the NMPA. If rejected, corrections are required. Once approved, the registration of the import and sale can be announced.
Additional documents may be requested during a second review. If approval is granted, the NMPA issues the electronic registration form and import and sales approval.
Time frame
- General cosmetics: 3–4 months
- Special cosmetics: 3–6 months for each review phase; additional technical review by the NMPA required
New requirements for cosmetics registration in China
- From January 2021:Proof of a functioning quality management system
- From May 2021:List of all ingredients, including manufacturer, supplier, trade name
- From January 2022:Safety data for functional raw materials
- From January 2023: Safety data for all ingredients
In addition, proof of efficacy must be published on the NMPA’s online platform – depending on the product group, this may include literature, studies, clinical tests, or consumer tests.
Animal-free cosmetics
Since May 1, 2021, general cosmetics without animal testing may be sold in China through regular channels – not only via online platforms, but also in brick-and-mortar stores.
Parties involved
The applicant is usually the brand owner. They:
- produce themselves or commission other manufacturers
- are responsible for quality, safety, and efficacy
- implement a quality management system
- document and evaluate adverse effects
- appoint a qualified specialist with at least five years of professional experience
Responsible person in China
This person takes care of the registration on behalf of the foreign applicant – this could be the importer, distributor, or an agency, for example. Their tasks include:
- Registering products and new raw materials
- Monitoring safety aspects, recalls, and adverse reactions
- Communicating with Chinese authorities
- Provisional responsibility for product safety in China
Handling confidential information
Cosmetics registration requires the disclosure of sensitive data such as:
- Percentage formulations
- Manufacturing processes
- Raw material suppliers and specifications
This information is passed on to the designated person in China – a relationship of trust is therefore essential.
Tip: Instead of appointing a distributor, it may make more sense to work with a branch of a German company in China. This offers long-term stability and provides support with registration, product recalls, and the annual report to the NMPA.
Conclusion
Cosmacon GmbH develops cosmetic products for you that are not only effective and brand-compatible, but also take regulatory requirements – such as registration in China – into account from the outset. Take advantage of our expertise for efficient, targeted product development in international markets.