ZMUni Compliance Centre

According to relevant data, the market size of China's cosmetics industry in 2023 was approximately 516.9 billion yuan, showing a year-on-year growth of 6.4%. It is projected to reach 579.1 billion yuan by 2025. The vast and rapidly expanding Chinese market has become a key export destination. Countries like Japan, South Korea, Italy, France, and Germany are major sources of cosmetics imports to China. So, how can cosmetics successfully enter the Chinese market quickly and smoothly? This article provides a snapshot of the latest cosmetic application status and outlines the key compliance requirements for cosmetics exports to China.

Registration and Notification Data of Cosmetics from Major Countries in China

Cosmetic Registration/Notification Procedure in China

Special Cosmetics: The registration certificate for special cosmetics is valid for five years. To extend the registration, the registrant must submit an application between 90 and 30 working days before the certificate's expiration date.

General Cosmetics: After completing the notification and public disclosure, it is essential to monitor the product's status. During the technical review, rectification orders may be issued, and products with safety issues may be suspended. Additionally, an annual report must be submitted to the NMPA for general cosmetics that have been filed for over a year. This report is due between January 1 and March 31 each year.

Tips: 

For Japanese and South Korean Companies:

-Registration for special cosmetics typically takes 10-12 months, while hair loss products may take around 12-14 months.

-Notification for general cosmetics usually takes 2-4 months.

List of Required Documents

• Cosmetic registration and notification information form

• Product name

• Product formulation

• Product quality specification

• Product label

• Product testing report

• Product safety report

• Certificate of free sales

• For imported products where the formulation is specifically designed for the Chinese market (excluding those commissioned for production abroad), the following materials must be submitted:

i. Documentation explaining the formulation design based on Chinese consumers' skin types and consumer needs;

ii. Materials from consumer testing studies or human efficacy trials conducted in China with Chinese consumers.

Animal Testing Exemption

Cosmetics commonly claim to be free from animal testing internationally, while in China, the Provisions for the Management of Cosmetic Registration and Notification Dossiers outline specific situations where animal testing can be exempted.

For general cosmetics, manufacturers that have obtained Good Manufacturing Practice (GMP) certification from the competent authorities of their country or region, and where product safety risk assessments confirm the product’s safety, may be exempt from submitting toxicological test (animal testing) reports. However, exemptions do not apply in the following cases:

• Products intended for use by infants and children.

• Products containing new cosmetic ingredients still under safety monitoring.

• If the filer, domestic responsible party, or manufacturer is classified as a high-priority regulatory target based on quantitative grading results.

If multiple manufacturers are involved, all must have obtained GMP certification from their respective authorities to qualify for exemption from submitting toxicological test reports.

Tips for Acceleration

• Confirm Eligibility for Animal Testing Exemption: Verify in advance whether the product qualifies for animal testing exemption and if the manufacturing facility can provide GMP certification from the relevant government authority.

• Formula Review: Prepare three reports—stability testing, packaging compatibility testing, and preservative challenge testing—in advance to address safety evaluation policies. This ensures product safety and quality, and if unable to submit before next year’s May Day, allows flexibility to submit a full safety evaluation application.

• Formula Compliance Review: Conduct a formula compliance review during development to ensure the formula adheres to China’s regulatory requirements.

• Claims Verification: Identify the key marketing focus for the product in the Chinese market, then verify claims based on the original packaging. Tailor an efficacy testing plan accordingly.

Navigating the Complexities of China's Cosmetic Compliance

Cosmetic compliance is crucial but can be challenging. To navigate these complexities and ensure a smooth market entry, partnering with a professional service provider like us can make a significant difference. ZMUni Compliance Centre has extensive experience helping overseas companies export cosmetics to China. We offer comprehensive, one-stop solutions, covering everything from cosmetic ingredients and products to customs clearance services. For more information or assistance with accessing the Chinese market, please reach out to us at info@zmuni.com.

In relation to the above Export Compliance, ZMUni has compiled an e-book for easier reference. If you would like a copy, feel free to contact us via email.