What is Considered a Cosmetic Product in China?

Cosmetics refer to daily chemical products intended to be applied to human surfaces—such as skin, hair, nails, and lips—by rubbing, spraying, or similar methods for the purpose of cleansing, protecting, beautifying, or modifying appearance. (Cosmetics Supervision and Administration Regulations (CSAR), Chapter 1, Article 3)

Classification of Cosmetics

Cosmetics in China are divided into Special Cosmetics and Ordinary Cosmetics under CSAR. Special cosmetics require state registration, while ordinary cosmetics require filing.

• Special Cosmetics: Products designed for the function of hair dyeing, perming, spot removal/skin whitening, sunscreen, or anti-hair loss, as well as products claiming entirely new cosmetic functions.
• Ordinary Cosmetics: Any cosmetic product other than special cosmetics.

Note: Plain bar soaps are exempt from these regulations. However, any soap claiming special cosmetic functions (e.g., whitening or anti-hair loss) must fully comply with this regulation.

Qualification of Cosmetics Registrant and Filer

The cosmetics registrant or filer is in charge of the quality, safety, and efficacy claims of cosmetics. And it shall

• Be an enterprise or other organization established according to law;
• Have a quality management system suitable for the cosmetics to be registered and filed;
• Have an ability to adverse reactions monitoring and evaluation

Domestic Responsible Person

Foreign companies have to appoint a domestic responsible person to deal with the pre-market registration or filing application. The domestic responsible person shall

• Register and file the cosmetics or new cosmetic ingredients in the name of the registrant and filer;
• Assist registrants and filers in the monitoring of cosmetics adverse reactions, safety monitoring, and reporting of new cosmetic raw materials; 
• Assist registrants and filers in the recall of cosmetics and cosmetic ingredients;
• Undertake the corresponding safety and quality responsibilities of cosmetics and new cosmetic ingredients placed in the Chinese market according to the agreement between the responsible person and registrant/filer;
• Cooperate with the supervision and inspection work of the supervision departments

Who Shall Register?

• Companies who intend to sell cosmetics products via offline stores in China
• Companies who intend to sell cosmetics products via online platforms except cross-border e-commerce such as TMALL, JD, etc.,  

Application Types

There are two types of applications for cosmetics under CSAR: registration and filing:

Application Process

China Cosmetics Registration & Filing: Frequently Asked Questions for Industry

Q1. What are the qualifications for an overseas Quality & Safety Responsible Person?

A1. Under Article 8 of the Provisions on the Supervision and Administration of Enterprise Implementation of Primary Responsibility for Cosmetic Quality and Safety, the Quality & Safety Responsible Person must:

• Hold a degree in a relevant field (e.g., cosmetics, chemistry, chemical engineering, biology, medicine, pharmacy, food science, public health, or law).
• Be familiar with relevant laws, regulations, mandatory national standards, and technical specifications.
• Have at least 5 years of experience in cosmetics production or quality management.

NMPA Regulatory Clarification: According to Article 32, Paragraph 2 of CSAR, Thequalified experience should be evaluated in line with regulatory intent. Because quality management principles for health-related products are consistent across sectors, proven production or quality management experience in pharmaceuticals, medical devices, or special foods counts toward the 5-year requirement (provided the candidate meets the core educational criteria).

Q2. Is it available to change a Domestic Responsible Person?

A2. Yes. According to Article 48 of the Provisions on the Administration of Cosmetics Registration and Filing Documents, when changing the domestic responsible person, documents including the product list, a consent letter or legal authorization from the current domestic responsible person , and a letter of commitment letter from the new responsible person. 

Q3. What information must be displayed on a cosmetic e-label?

A3. Scanning the code must directly open the product details without intermediate conditions or intrusive pop-ups.

Required Content: Participating pilot enterprises must fully display all mandatory label details required under Article 7 of the Administrative Measures on Cosmetic Labeling. Content cannot exceed the approved product label draft.

Accessibility Features: Systems are encouraged to include text magnification and audio readouts to assist consumers.

Consumer Requests: Pilot enterprises must provide a complete Chinese label (in physical or digital format via post, email, or in-person) upon consumer request.

Q4. Is it available to submit a request fro formula changeif an error was made during filing?

A4. No. Under the Provisions on the Administration of Cosmetics Registration and Filing Documents, formula updates are strictly limited to scenarios where:

• The raw material manufacturer or technical specifications change.
• Trace additives (e.g., stabilizers, antioxidants, or preservatives) are adjusted solely to maintain raw material quality, provided the raw material ratio, active functional ingredients, and solvents remain identical

Errors caused by enterprise misreporting cannot be edited. You must cancel the current filing and submit a new application.

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