China Cosmetic Registration and Filing

Under Cosmetics Supervision and Administration Regulations (CSAR) issued in 2020, cosmetics are divided into special cosmetics and ordinary cosmetics. Special cosmetics are products for the function of anti-freckle/whitening, sunscreen, hair dye, hair perm, anti-hair loss and new efficacies. Ordinary cosmetics are cosmetics other than special cosmetics. Companies who plan to place cosmetics on Chinese market must apply for the registration or filing with the NMPA or provincial MPA to get approval license or filing certificate. Toothpaste will be regulated as ordinary cosmetics.

Qualification of Cosmetics Registrant and Filer

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

1. Be an enterprise or other organization established according to law;

2. Have a quality management system suitable for the cosmetics to be registered and filed;

3. Have an ability of adverse reaction monitoring and evaluation

Duty of Domestic Responsible Person

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

1. Register and file the cosmetics or new cosmetic ingredients in the name of the registrant and filer;

2. Assist registrants and filers in the monitoring of cosmetics adverse reaction, safety monitoring and reporting of new cosmetic raw materials;

3. Assist registrants and filers in the recall of cosmetics and cosmetic ingredients;

4. 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;

5. 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 application for cosmetics under CSAR: registration and filing:

Registration of special cosmetics	All special cosmetics have to be registered with NMPA. Approval license will be issued once passing both the format and technical review of NMPA. The registration license is valid for 5 years. The soaps with the function of special cosmetics are subject to the management of special cosmetics.
Filing of ordinary cosmetics	Generally the electronic filing certificate will be issued if passing the official review of submitted dossiers by NMPA or provincial MPA. Annual report will be required for ordinary cosmetics to submit from Jan 1 to Mar 31 of each year since 2022.

Application Process

Our Services

Registration of Special Cosmetics/Filing of Ordinary Cosmetics

Acting as domestic responsible person for the application of user rights of online registration and filing system Determining the type of cosmetics so as to confirm what kind of notification required Preliminary review of formula and label so as to check if complying with the regulatory requirements for the cosmetic ingredients and efficacy claim Regulatory compliance testing in product safety and efficacy according to Safety and Technical Standards for Cosmetics 2021 and Specification for the Evaluation of Cosmetic Efficacy Claims Full dossiers preparation and submission