China Cosmetic Registration & Filing/Notification | NMPA Compliance Guide

What is China Cosmetic Registration and Filing/Notification?

China’s cosmetic regulatory framework is built on the Cosmetic Supervision and Administration Regulation (CSAR) and its supporting rules. CSAR was promulgated on June 29, 2020 and came into force on January 1, 2021.

Under China's CSAR framework, all cosmetic products imported or sold in mainland China must undergo a pre-market compliance procedure. The regulatory pathway is determined by the product classification, origin, claims, formula, target users, and sales channel.

• China Cosmetic Registration (Special Cosmetics)

Including hair dyes, hair perming products, freckle-removing and whitening cosmetics, sunscreens, anti-hair loss products, and cosmetics claiming new efficacy. These products must obtain registration approval before production or import and are subject to registration testing, safety assessment, efficacy claim substantiation, technical review, and post-market compliance obligations.

• China Cosmetic Notification / Filing (General Cosmetics)

Imported general cosmetics must complete filing before import, while domestic general cosmetics must complete filing before being placed on the market. Filing is not an approval process, but filed products remain subject to post-filing review, annual reporting, sampling inspections, adverse reaction monitoring, and other post-market obligations.

In industry practice, “filing” is sometimes referred to as “notification.”

Do You Need NMPA Registration or Filing Before Selling Cosmetics in China?

Companies should complete a China regulatory pathway assessment before collecting dossiers, arranging product testing, finalizing packaging, or confirming a launch date.

You should assess China cosmetics registration or filing requirements if your company plans to:

• Import cosmetics into mainland China through general trade;
  

• Manufacture cosmetics in China for domestic sale;
  

• Launch skincare, makeup, cleansing products, perfumes, shampoos, conditioners, masks, or similar cosmetic products;
  

• Register sunscreen, freckle-removing and whitening, anti-hair loss, hair dye, or hair perming products;

• Sell children’s cosmetics in China;
  

• Move products from cross-border e-commerce to general trade;
  

• Change a product formula, label, manufacturer, brand owner, or Domestic Responsible Person;
  

• Review whether a product is a cosmetic, drug, medical device, disinfection product, toothpaste, or another regulated product type in China.
  

Products Covered by China Cosmetic Registration and Filing/Notification

China cosmetic product registration and filing apply to cosmetics manufactured, imported, or sold in China through general trade.

Under China’s cosmetic regulatory framework, whether a product is a cosmetic depends not only on its product name, but also on its application area, route of use, intended purpose, product form, and label claims.

Common products that may fall under China cosmetic regulation include:

• Skincare products, cleansers, masks, lotions, creams, serums, makeup, perfumes, shampoos, conditioners, and bath products;

• Sunscreens,  freckle-removing and whitening products, anti-hair loss products, hair dyes, and hair perming products;

• Toothpaste, which is currently regulated with reference to general cosmetics requirements;

• Beauty device gels, ampoules, oral care products, soaps, patches, and similar products, which require case-by-case classification based on use and claims.

Special cosmetics must obtain registration approval before production or import.  Imported general cosmetics must complete filing before import, and domestic general cosmetics must complete filing before market launch.

Key Parties Responsible for China Cosmetic Registration and Filing

China cosmetic compliance involves several parties across the product responsibility chain.

Registrant or Notifier

The registrant or notifier is usually the brand owner or market authorization holder. It is responsible for product quality and safety, efficacy claims, dossier authenticity, dossier completeness, and traceability.

For imported cosmetics, and for products where the registrant or notifier is an overseas enterprise, the overseas registrant or notifier must designate a qualified enterprise legal person in China as the Domestic Responsible Person.

Domestic Responsible Person in China

The Domestic Responsible Person handles registration or filing matters on behalf of the overseas registrant or notifier and supports adverse reaction monitoring, product recall, regulatory communication, inspection response, and other post-market obligations.

Overseas brands should confirm the responsible person arrangement before starting the project, as unclear authorization, inconsistent company information, or an unsuitable responsible person may delay the submission.

Manufacturer

The manufacturer may be the brand’s own factory or an OEM/ODM manufacturer. It must provide production qualification documents, quality management documents, production information, and other required materials. The final product must be manufactured in accordance with the registered or notified dossier and product technical requirements.

Importer, Distributor, or Operator

Importers and distributors should verify product information, Chinese labeling, supply chain documents, purchase inspection records, sales channel compliance, and post-market cooperation responsibilities.

How to Choose a China Domestic Responsible Person

Overseas cosmetic registrants and filing persons must designate a qualified enterprise legal person in China as the Domestic Responsible Person.

The Domestic Responsible Person supports:

• Registration and filing matters on behalf of the overseas company;
  

• Adverse reaction monitoring;
  

• Product recall;
  

• Regulatory communication;
  

• Inspection response;
  

• Post-market compliance cooperation.

Choosing the right Domestic Responsible Person is important because it may affect dossier control, distributor independence, regulatory communication, and long-term compliance management.

REACH24H can support overseas brands with Domestic Responsible Person arrangement, authorization review, submission coordination, dossier maintenance, and post-market compliance management.

Documents Required for China Cosmetic Registration and Filing

The required dossier depends on product type, origin, claims, formula, manufacturer, responsible person arrangement, and existing data. Common documents include:

Before submission, REACH24H recommends conducting a dossier gap analysis covering classification, formula, label, testing, safety assessment, efficacy claims, import documents, and dossier consistency.

Step-by-Step NMPA Cosmetic Registration and Filing Process

General Cosmetics Filing / Notification Process

1. Product classification and regulatory pathway assessment

2. Confirmation of registrant/notifier, manufacturer, and domestic responsible person

3. Formula, ingredient safety information, and restricted substance review

4. Original packaging review

5. Chinese and foreign product name review

6. Testing item confirmation and sample testing

7. Review of production process, quality control, and claim substantiation documents

8. Dossier preparation

9. Safety assessment preparation

10. Online submission through the registration and filing platform

11. Completion of filing and market entry

12. Post-notification review, annual report, change management, and ongoing compliance maintenance

General cosmetics filing does not mean the product is free from future obligations. Companies must continue to manage annual reporting, post-notification review, product changes, label updates, adverse reaction monitoring, and regulatory inspections.

Special Cosmetics Registration Process

1. Special efficacy assessment and registration strategy

2. Formula, safety, efficacy, and label pre-review

3. Testing and efficacy claim substantiation plan

4. Registration dossier preparation and online submission

5. Formal review and technical review

6. Supplementary response and authority communication

7. Approval and issuance of the special cosmetics registration certificate

8. Certificate renewal, change management, and post-market compliance maintenance

Special cosmetics registration usually requires a longer lead time and more technical evidence. Sunscreen, whitening/spot-removing, anti-hair loss, hair dye, and hair perm products should be planned early due to testing, efficacy evaluation, safety assessment, and technical review requirements.

2026 Policy Update: Key Changes to China Cosmetic Registration and Notification

On July 29, 2026, China’s National Medical Products Administration (NMPA) issued the Announcement on Matters Concerning Cosmetics Registration and Notification (NMPA Announcement No. 70 of 2026), introducing multiple measures to optimize cosmetic registration and notification management.

For brands, manufacturers, and importers planning to enter the China market, the following changes are particularly important:

1. Expanded Scope of Animal Testing Exemptions

Subject to applicable conditions, the scope of animal testing exemptions has been further expanded. In addition to previously eligible cases, certain special cosmetics and general cosmetics using new cosmetic ingredients (excluding children’s cosmetics) may now benefit from more flexible animal testing exemption arrangements.

2. Data Sharing for Products with Similar Formula Systems

For products within the same series, multiple shades, or with similar formula systems, certain safety testing data and efficacy claim evaluation data may be shared when the applicable conditions are met. Safety assessments, however, must still be conducted on a product-specific basis in accordance with relevant principles and cannot simply be reused without targeted analysis.

3. Ingredient Safety Information Shifted from System Submission to Record Retention

For cosmetic registration and notification, companies are no longer required to enter ingredient safety information documents or ingredient submission codes in the system; only the name of the ingredient manufacturer needs to be provided. Relevant ingredient safety documentation must instead be retained by the company for inspection.

4. More Flexible Cross-Border Production Site Changes and Domestic Responsible Person Changes

For registered or notified products, where the applicable conditions are met, a cross-border transfer of a production site or the addition of a production site may allow certain existing testing and evaluation data to be reused, with supplementary testing conducted as required. Documentation requirements for changing the Domestic Responsible Person have also been further simplified.

5. Facilitated First Launch of New International Cosmetic Products in China

For new international cosmetic products first launched in China, or launched simultaneously in China and other countries or regions, companies may, in accordance with the applicable requirements, be exempt from submitting a certificate of free sale (CFS) from the country or region of origin. Instead, they may submit a commitment statement for first launch in China; sales packaging for the country or region of production may be submitted as a design drawing at the registration or notification stage.

6. Broader Acceptance of Efficacy Claim Evaluation Test Methods

For efficacy claims other than freckle-removing and whitening, sunscreen, and anti-hair loss claims, registrants and notifiers may, where supported by sufficient scientific evidence, independently select industry standards, international standards, technical guidelines, or validated in-house methods to conduct efficacy claim evaluation testing.

Timeline and Cost Drivers

The timeline and cost of China cosmetic registration or filing vary depending on product type, dossier readiness, testing requirements, efficacy claim evaluation, safety assessment complexity, label correction, and import document preparation.

Major factors include:

• Product category: special cosmetics generally require more time and resources than general cosmetics.

• Imported vs domestic products: imported products involve additional foreign documentation, translations, authorizations, and responsible person arrangements.

• Efficacy claims: sunscreen, freckle-removing and whitening, anti-hair loss, anti-acne, repairing, and nourishing claims may require additional testing and evaluation.

• Testing scope: dependent on dosage form, application area, target users, and claims.

• Safety assessment difficulty: complex formulas and incomplete ingredient information can extend preparation time.

• Label corrections: non-compliant labels may delay packaging production and dossier submission.

• Ingredient safety information: ingredient safety information documents and ingredient submission codes no longer need to be entered in the registration/notification system under NMPA Announcement No. 70 of 2026. Relevant materials should be retained for inspection, and incomplete ingredient manufacturer or supplier information may still create dossier gaps.

• Domestic responsible person arrangement and legacy product status: late or unclear arrangements, or changes in formula, label, or manufacturers, may require separate assessment and filing.

Submit your product name, formula, label, claims, and origin to receive a preliminary assessment of timeline and budget for your China cosmetic project.

Post-Market Compliance Obligations After Registration or Filing

China cosmetic compliance does not end after filing completion or registration approval.

Companies must continue to manage:

• Annual reporting for general cosmetics;
  

• Renewal of special cosmetics registration certificates;
  

• Change management for formula, label, manufacturer, responsible person, and other product information;
  

• Maintenance of efficacy claim substantiation documents;
  

• Updates to safety assessment documents;
  

• Adverse reaction monitoring and reporting;
  

• Response to post-filing review, inspections, and sampling tests;
  

• Product discontinuation, cancellation, re-filing, or re-registration assessment;
  

• Import authorization and certificate management.
  

REACH24H provides long-term compliance maintenance for registered and filed cosmetic products in China.

How REACH24H Can Support

REACH24H provides full-process support for overseas and domestic cosmetic companies entering the China market.

• Product classification and market access assessment;
  

• Imported cosmetics registration and filing;
  

• Domestic cosmetics registration and filing;
  

• Domestic Responsible Person support;
  

• Formula and ingredient compliance review;
  

• Ingredient manufacturer information and ingredient safety information record-retention review;

• Original packaging review;
  

• Chinese label review;
  

• Testing coordination;
  

• Safety assessment report preparation or review;
  

• Efficacy claim evaluation;
  

• Registration and filing dossier preparation;
  

• Online submission and authority communication;
  

• Supplementary response support;
  

• Cross-border transfer and addition of production sites – assess whether testing data may be reused, evaluate substantive changes to product executive standards, and coordinate microbiological and physicochemical testing for the new site;

• Annual reporting, renewal, change management, cancellation, and post-market compliance maintenance.

Why Choose REACH24H?

Extensive Experience Across China Cosmetic Registration and Filing Projects

Founded in 2009, REACH24H has extensive experience supporting cosmetic companies with China market access and product lifecycle compliance.

Our China cosmetics practice covers domestic and imported general cosmetic filings, domestic and imported special cosmetic registrations, toothpaste filing, new cosmetic ingredient registration and filing, testing arrangement and coordination, and Domestic Responsible Person support for overseas companies.

As of July 2026, our cosmetics team has completed thousands of general cosmetic filing projects and supported domestic and imported projects involving sunscreens, freckle-removing and whitening cosmetics, hair dyes, hair perming products, anti-hair loss products, children’s cosmetics, toothpaste, and new cosmetic ingredients.

Our project experience spans pre-market assessment, registration or filing, technical review, and post-market compliance. Depending on the product and applicable regulatory pathway, REACH24H can support companies with regulatory applicability assessment, formula and ingredient compliance review, cosmetic safety assessment, efficacy evaluation strategy, testing, dossier preparation, registration and filing submissions, responses to technical review questions, post-market changes, annual reporting, renewals, and ongoing compliance management.

This experience enables our team to identify and manage potential regulatory and technical issues throughout the product lifecycle, from product development and market entry to ongoing compliance after launch.

Hands-On Experience with Special Cosmetics and Complex Product Scenarios

Beyond routine general cosmetic filings, REACH24H has extensive experience with special cosmetics and other technically complex product scenarios.

Our project experience includes special cosmetics such as:

• Sunscreen products;

• Freckle-removing and whitening cosmetics;

• Hair dyes;

• Hair perming products; and

• Anti-hair loss products.

REACH24H has also supported technically complex projects involving children’s cosmetics, multi-shade product ranges, product sets and kits, and finished cosmetic products formulated with new cosmetic ingredients.

For these projects, our teams can provide support covering product classification and regulatory pathway assessment, formula and ingredient compliance, cosmetic safety assessment, efficacy evaluation, testing strategy and coordination, dossier preparation, and responses to technical review questions.

Through long-term project practice, REACH24H has established structured procedures for dossier preparation, internal technical review, and regulatory response management. Cross-functional specialists can be involved at critical project stages to strengthen consistency among formula information, toxicological data, safety assessment conclusions, test results, and submission documentation.

Our teams have supported projects involving companies and filing entities across Zhejiang, Shanghai, Beijing, Guangdong, Shandong, Yunnan, Chongqing, Jiangsu, and other regions of China. This experience provides practical familiarity with provincial filing and implementation procedures where applicable, while special cosmetic registrations follow the applicable national registration pathway.

Based on the filing location, product type, and applicable regulatory pathway, REACH24H can develop practical project plans tailored to the specific requirements and implementation conditions of each project.

REACH24H also supported Beiersdorf Group in securing the registration of Thiamidol, the first freckle-removing and whitening new cosmetic ingredient registered under China’s current cosmetics regulatory framework. The project provided practical experience spanning new ingredient safety assessment, registration, and compliance considerations for subsequent use in finished cosmetic products.

42 Dedicated Cosmetic Compliance Experts and Strong Safety Assessment Capabilities

As of July 2026, REACH24H’s cosmetics compliance team consists of 42 dedicated technical experts, with expertise covering formula assessment, toxicology, cosmetic safety assessment, efficacy evaluation, regulatory dossier review, and responses to technical review questions.

The team includes professionals with backgrounds and professional credentials in toxicology and cosmetic safety assessment, including:

• Diplomates of the Chinese Society of Toxicology (DCST);

• European Registered Toxicologists (ERT);

• Toxicologists registered with the UK Register of Toxicologists (UKRT);

• Diplomates of the American Board of Toxicology (DABT); and

• Professionals with qualifications or training relevant to EU cosmetic safety assessment.

For special cosmetics, new cosmetic ingredients, and other high-complexity projects, REACH24H applies a cross-functional expert review mechanism. Specialists from different technical disciplines can jointly review critical project stages to strengthen consistency and completeness across formula assessment, toxicological evaluation, cosmetic safety assessment, testing, and regulatory documentation.

REACH24H has also developed an internal cosmetic safety assessment database, which continuously accumulates technical information relating to ingredient toxicology, exposure, use concentrations, and risk assessment.

These resources support ingredient safety analysis, exposure assessment, and the preparation and review of cosmetic safety assessment reports.

Global Cosmetics Compliance Support Through Nine Branches

REACH24H operates a global service network across Asia, Europe, and North America, with nine branches and local teams in:

• Hangzhou, China;

• Taiwan, China;

• Washington, D.C., United States;

• Dublin, Ireland;

• London, United Kingdom;

• Seoul, South Korea;

• Tokyo, Japan;

• Hanoi, Vietnam; and

• Singapore.

In addition to cosmetic registration and filing in China, REACH24H supports companies with regulatory compliance and market access projects in major cosmetics markets including the European Union, United Kingdom, United States, Japan, South Korea, ASEAN markets, Australia, Canada, Taiwan, China, and the United Arab Emirates (UAE).

For companies planning launches across multiple countries or regions, REACH24H can work from an existing core product information package and assess how it needs to be adapted for each jurisdiction. Depending on the market, this may involve differences in product classification, ingredient restrictions, safety assessment, labeling, local responsible entities, and registration, filing, or notification requirements.

With centralized project management and cross-regional team coordination, companies do not need to engage a different service provider for each individual market. This can reduce duplicated regulatory research and repeated preparation of the same core product information while making it easier to coordinate compliance timelines across markets and align regulatory activities with regional and global product launch plans.

As of July 2026, REACH24H has provided regulatory compliance and market access services in one or more jurisdictions to more than 2,000 cosmetics-related companies worldwide, including Fortune Global 500 companies such as Beiersdorf, Shiseido, and Unilever.

REACH24H has also been recommended by foreign embassies and consulates in China and industry associations as a regulatory and technical service provider.

Cross-Disciplinary Support from Ingredients and Finished Products to Packaging and Third-Party Programs

REACH24H’s capabilities extend beyond finished cosmetic product registration and filing.

Our services also cover cosmetic ingredients, chemical regulatory compliance, packaging and sustainability requirements, and regulatory support for third-party certification, verification, and recognition programs.

This enables brands, manufacturers, and ingredient suppliers to obtain coordinated regulatory support across multiple stages of the product value chain, from upstream ingredient compliance and product development to finished-product market access.

Related capabilities include:

• Cosmetic ingredient and related chemical regulatory compliance;

• SDS preparation and global chemical hazard communication;

• Cosmetic product registration, filing, notification, and market access in China and overseas markets;

• Packaging and sustainability compliance, including the EU Packaging and Packaging Waste Regulation (PPWR); and

• Regulatory consulting and documentation support for third-party certification, verification, and recognition programs, including EWG VERIFIED®, Halal, PETA, and Leaping Bunny.

For projects involving multiple regulatory areas—such as ingredient compliance, finished-product market access, packaging requirements, sustainability regulations, and overseas launches—REACH24H can coordinate core product information, technical documentation, and key project milestones through a unified project team.

This cross-disciplinary approach can reduce the need to repeatedly transfer formula, ingredient, safety, packaging, and product information among multiple service providers. It can also help minimize potential compliance risks caused by inconsistent information across different regulatory workstreams.

By connecting regulatory support across ingredients, finished products, packaging, sustainability, and international market access, REACH24H helps companies build a more coordinated compliance process from ingredient selection and product development through registration or filing and global market launch.

FAQ

Get a China Cosmetic Registration and Filing Assessment

If you are preparing to import cosmetics into China, launch domestic cosmetics, register sunscreen or whitening products, notify children’s cosmetics, or transition cross-border e-commerce products into general trade, REACH24H can help you assess the correct pathway and identify dossier gaps.

Submit your product information to assess the timeline, cost, and regulatory pathway for China cosmetic product registration or filing.

Official Regulatory Resources for China Cosmetic Compliance

For companies seeking official references, the following resources are useful starting points:

• NMPA Cosmetics Portal – official NMPA cosmetics regulatory updates and resources.

• Cosmetic Supervision and Administration Regulation (CSAR) – the overarching administrative regulation for China cosmetics supervision.

• Provisions for Registration and Filing of Cosmetics – core rules for cosmetic registration and filing management.

• Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics – rules covering manufacturing, marketing, and post-market supervision.

• NMPA Announcement on Several Measures to Optimize the Management of Cosmetic Safety Assessment – policy updates on cosmetic safety assessment management.

• Policy Interpretation of the NMPA Announcement on Measures to Optimize the Management of Safety Assessment of Cosmetics – interpretation of the safety assessment optimization measures.

• NMPA Announcement on Issuing the Provisions for the Supervision and Administration of Children’s Cosmetics – official regulatory basis for children’s cosmetics management.

Related REACH24H Services and Insights

For further support, companies can refer to the following REACH24H English resources:

China Cosmetic Product Registration or Notification/Filing – full-process support for imported and domestic cosmetic products.

China New Cosmetic Ingredients Registration or Notification/Filing – support for ingredients not listed in IECIC or subject to new cosmetic ingredient requirements.

China’s Cosmetic Ingredient Submission Code – support for ingredient safety information and submission code requirements.

China’s Cosmetic Safety Assessment Report – safety assessment report preparation and review support.

Efficacy Claim Evaluation Report – efficacy claim evaluation and evidence support for China cosmetics compliance.

China Toothpaste Notification – toothpaste filing and compliance support.

Navigating Perfume Compliance in China – perfume compliance and notification/registration support.

China NMPA Finalizes Measures to Optimize Cosmetic Registration and Notification Management – NMPA Announcement No. 70 of 2026, including animal testing, ingredient information, and cross-border registration/notification changes.