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Navigating Cosmetic Registration and Filing in China: What You Need to Know

China has become a key market for the global cosmetics industry, largely due to its rapidly growing economy, expanding middle class, and increasing consumer interest in health and beauty. Cosmetics in China are classified into two categories: special cosmetics and ordinary cosmetics. Special cosmetics include products for specific functions such as skin whitening, sunscreen, hair dyeing, and anti-hair loss, while ordinary cosmetics cover all other products. Companies looking to introduce cosmetics into the Chinese market must apply for either registration or filing with the National Medical Products Administration (NMPA) or provincial MPAs to obtain the necessary approval or filing certificates. Toothpaste is categorized as an ordinary cosmetic.

Who Can Register or File Cosmetics?

The entity responsible for registration or filing must oversee the safety, quality, and efficacy claims of the cosmetics. The qualifications for this entity include:

  1. The entity must be a legally established organization or enterprise;
  2. It should have a quality management system suitable for the cosmetics being registered or filed;
  3. It must be capable of monitoring and evaluating adverse reactions.

Domestic Responsible Person

Foreign companies must appoint a domestic responsible person in China to handle the pre-market registration or filing process. The responsibilities of this person include:

  1. Registering and filing the cosmetics or new cosmetic ingredients on behalf of the registrant or filer;
  2. Assisting in the monitoring and reporting of adverse reactions, safety issues, and new cosmetic raw materials;
  3. Managing the recall process for cosmetics and ingredients when necessary;
  4. Taking on the safety and quality responsibilities of cosmetics and ingredients as per the agreement with the registrant/filer;
  5. Cooperating with government supervision and inspection authorities.

Who Needs to Register?

  • Companies intending to sell cosmetics in physical stores across China
  • Companies planning to sell cosmetics online, excluding cross-border e-commerce platforms like Tmall, JD, etc.

Types of Applications

Under the CSAR, there are two primary application types for cosmetics: registration and filing.

Registration of Special Cosmetics
  • The registration license is valid for 5 years.
  • Soaps that have special cosmetic functions are regulated as special cosmetics.
Filing of Ordinary Cosmetics
  • If approved, the electronic filing certificate will be issued by NMPA or provincial MPA.
  • Annual reports for ordinary cosmetics will be required, to be submitted from January 1 to March 31 every year starting from 2022.

Application Process

China, Cosmetics, Registration, Filing, Supervision, Ordinary, Special

Our Services

Special Cosmetics Registration / Ordinary Cosmetics Filing
  • Acting as the domestic responsible person for registration and filing
  • Determining the correct cosmetic classification and necessary notification
  • Preliminary review of formulas and labeling to ensure compliance with regulatory standards
  • Regulatory compliance testing for product safety and efficacy
  • Preparing and submitting full regulatory dossiers

Further Information

For more details, please refer to the official safety assessment reports or contact our experts for assistance with the cosmetic registration process.

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