ZMUni Compliance Centre

Why is a China Responsible Person Required?

According to China's Cosmetic Supervision and Administration Regulation (CSAR), overseas cosmetic registrants and notifiers must appoint a China Responsible Person (RP) in mainland China.

The China RP serves as the local representative for overseas companies and supports communication with Chinese regulatory authorities, as well as cosmetic compliance activities required for market entry and post-market management.

What Can Be Delegated to a China Responsible Person?

By appointing a China RP, overseas companies can rely on the RP to support the following activities:

• Submit cosmetic registration and notification applications on behalf of overseas registrants/notifiers.

• Manage communication with regulatory authorities regarding cosmetic registration and notification matters.

• Assist with product testing, documentation submission, and compliance procedures.

• Support adverse reaction monitoring and reporting activities.

• Assist with product recall procedures when required.

• Support regulatory inspections and follow-up communication.

The overseas registrant/notifier remains responsible for ensuring product safety and regulatory compliance in accordance with China’s cosmetic regulations.

Requirements for a China Responsible Person 

A China RP must:

• Be a company legally registered in mainland China with independent legal entity status.

• Have cosmetic-related business activities and import/export activities included in its business scope.

The China RP does not have to be the product distributor. It can be designated by the brand owner from among distributors, subsidiaries, or qualified third-party service providers.

China Responsible Person Authorization Process

Step 1: Prepare Authorization Documents

The overseas registrant/notifier shall prepare the Letter of Authorization for China Responsible Person according to applicable requirements.

Step 2: Submit Authorization Documents

The China RP submits relevant documents through the NMPA Cosmetic Registration and Notification Information Service Platform, including:

• Letter of Authorization for China Responsible Person

• China Responsible Person Information Form

• Manufacturer Information Form

• Quality management system information

• Adverse reaction monitoring and evaluation system information

• Relevant qualification documents of the overseas registrant/notifier and manufacturer

Step 3: Account Approval and Product Applications

After account approval, the China RP can complete cosmetic registration/notification procedures and related compliance activities on behalf of the overseas company.

Letter of Authorization for China Responsible Person

The Letter of Authorization should include:

• Names of the overseas registrant/notifier and China RP

• Authorization scope

• Authorization period

The same product cannot be assigned to multiple China RPs. The China RP shall perform authorized activities within the agreed scope.

Change or Renewal of China Responsible Person

The China RP authorization should be renewed when the authorization period expires.

A change of China RP generally requires:

• Product list affected by the change

• Consent document from the previous China RP or relevant legal documents

• Commitment letter from the new China RP regarding compliance responsibilities

Our China Responsible Person Services

• China Responsible Person Appointment

• Cosmetic Registration & Notification Support

• Regulatory Communication Support

• Adverse Reaction Monitoring Support

• Product Recall Assistance

• Regulatory Consulting Services