What are the regulations to sell cosmetic products in China?

Cosmetics industry in China in 2020

In 2019, the online retail sales value of cosmetic products in China amounted to approximately 194.4 billion yuan. It’s an extremely profitable industry, in fact, this number was forecasted to exceed 350 billion yuan by 2024.

The Chinese cosmetic industry is the fastest-growing market in the world in recent years. The main consumer groups for cosmetic products are between the post-80 and post-90 generations, who are highly aware of product updates and have a strong inclination towards the appearance and trends.

As a result, several cosmetic brands have witnessed the collaboration with KOL and beauty bloggers and have incorporated advertisements to increase cosmetic sales.

Although the Chinese cosmetics market looks like a promising market with great opportunities, it also comes with its challenges. The registration process in China can be overwhelming if you are not well acquainted with cosmetics regulation. It is important to know the regulation well enough in order to ensure compliance and avoid any unnecessary problems with the authorities.

Cosmetics regulations to enter the Chinese market

In China, the most important cosmetic legislation is Regulations Concerning Hygiene Supervision over Cosmetics. The main authority for cosmetics is National Medical Products Administration (NMPA).

Both domestic and imported cosmetic products require pre-market approval or notification before they can be placed on the Chinese market.

To enter into the Chinese market, a few steps must be taken to ensure compliance with China cosmetics regulations:

Appoint a Chinese responsible agent

A foreign company must appoint a Chinese agent to apply for the NMPA license in a written power of attorney. In fact, the company cannot register its cosmetic products on its own.

The responsible Chinese agent may be a Chinese subsidiary, distributor, or third party (e.g. a consultancy company). It is essential to consider the pros and cons before choosing your agent.

REGISTRATION- All imported cosmetic products must be approved by the NMPA

Cosmetics products classification

According to Reach24H, cosmetic products are divided into two categories:

Non-special use cosmetics (non-SUC)

Non-special use cosmetics include skincare products, hair care products, nail care products, make-up and perfumes.

Non-SUC products require a pre-market filing and can be imported after the filing has been finished while the technical review is carried out during post-market surveillance.

Registration process includes:

  • Appoint a responsible agent in China
  • Product dossier
  • Submit dossier to NMPA for administrative review
  • Technical review
  • Registration certificate  
  • Importation
Special use cosmetics (SUC)

Special use cosmetics include products such as hair growth products, hair dyes, hair perming products, depilating products, breast beauty products, slimming products, deodorants, freckle-removing products, sunscreens, and whitening products.

According to CE.way, imported SUC products require a pre-market registration and can only be imported after getting approval from NMPA.

The filing process includes:

  • Appoint a responsible person in China
  • The responsible agent applies for NMPA account
  • Prepare dossier
  • Submit dossier to NMPA for administrative review
  • E-filing certificate
  • Importation
  • Technical review

Soaps, toothpaste, and oral cleansers are not considered cosmetics and they can be imported directly into China after customs clearance.

Regulatory requirements for non-special use cosmetics and special use cosmetics are different depending on whether they are domestic or imported products.

Cosmetics ingredients classification Regulation in China

Some products may fall into both categories and their classification depends on their composition.

In China cosmetics ingredients are classified into two types of:

  1. Existing cosmetic ingredients which can be found on the list called Inventory of Existing Cosmetic Ingredients in China (IECIC).
  2. New ingredients: Cosmetics that contain new ingredients require separate pre-approval from the NMPA before it can be introduced in cosmetic products destined for the Chinese market. If three years pass without incident, then the new ingredient is included in the catalog of ingredients accepted for use in cosmetics production in China.

TESTING- Cosmetics must be tested in NMPA-designated testing Institutions in China

Even if your cosmetics have been tested overseas, you still need to send your cosmetics to a designated NMPA testing institute in China for testing.

For all cosmetics, hygiene safety tests are mandatory. Tests might include a sanitary chemical test, microbiological test, toxicological test, and human safety tests.

Animal testing is required for imported cosmetics products, but has been waived for domestic non-special use cosmetics since 2014. Anyway, China is reducing the requirements for animal testing for cosmetics and is working on establishing alternative methods and verification institutions.

Labeling – in accordance with the Regulations

Prepare the labels for your cosmetic products in accordance with the Regulations on Cosmetic Label Management and the National Standard: GB 5296.3-2008 General Labelling for Cosmetics.

According to the 2008 Chinese regulations on the administration of cosmetic labeling, a complete list of ingredients must be reported on all cosmetic product labels. The ingredients must be listed in Chinese. The provisions also regulate the formatting of cosmetic labels and the content allowed or prohibited to be indicated on the labels.

The manufacturer has to list the following information, in Chinese, on the product’s label:

  • Product name
  • Name and address of the manufacturer
  • Net content
  • Product ingredients
  • Shelf life
  • Manufacturer license, product standard or administrative approval code
  • Safety marks and product literature

According to China’s 2010 Naming Requirements for Cosmetics, the name of a cosmetic product should be concise and easily understandable. It must not intentionally mislead or deceive consumers.

The Cosmetics Naming Guidelines list expressions prohibited in cosmetic product names. Banned expressions include:

  • “Special effect”
  • “Total effect”
  • “Powerful effect”
  • “Absolutely natural”
  • Others

Product names must not explicitly or implicitly indicate a false medical effect by using expressions such as:

  • “anti-bacterial”
  • “bacteria-inhibiting”
  • “anti-allergic”
  • “hair-regenerating”
  • “face-slimming”
  • others

In addition, the names of celebrities in the medical field are not allowed to be used in product names.

Custom clearance

After the above steps have been completed, the products may be imported into China and are subject to the import inspection and quarantine at the port of entry.

The importer needs to show the hard copy of the NMPA license and provide the port Certificate of inspection with:

  • Licenses and hygiene certificates
  • Safety assessment data on materials with potential safety risks
  • Certification that allows production and sale in the country of origin
  • Certificate of origin
  • Digital code
  • Sample of Chinese label and foreign label
  • Information on the quantity and weight of the product

Imported cosmetics are subject to import tariffs. Different cosmetic products in China are tariffed at different rates. For example, in China import tariff rate of skincare products is 1%, while makeup products are 5%.

GMA provide a wide choice of marketing and promotion solution to help you grow your business in China. We offer a complete panel of solutions: digital, marketing, and distribution services for consumer goods, in beauty, cosmetics, healthcare products, and fragrance. Contact us!

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