Import cosmetics into China

How to import cosmetics into China?

You want to import cosmetics into China but you don’t know what regulations you have to comply with? This is exactly why the experts of Sino Shipping have created this article. Indeed, you will find reliable information about the procedure you have to follow to import your products into China depending on the nature of the cosmetics. If you have any further questions, don’t hesitate to ask to one of our experts.


1/ Classifications of cosmetics

Cosmetic products are classified into two categories:

  • Non-special use cosmetics that include hair care, nail care, skin care, perfumes, and makeup.
  • Special use cosmetics that include namely products for hair growth, hair dye, hair perm, hair removal, breast shaping, fitness, deodorizing, spot removal, whitening and sun screen protection.

Non-special use cosmetics made abroad require a record-keeping certificate

*Special use cosmetics require a hygiene license, both issued by CFDA to abide by the cosmetics regulations in China before entering the market.

1.1 When it comes to new ingredient

New cosmetic ingredients gather all ingredients that are introduced on the Chinese market for the first time, as stated in article 9 of the Regulation for the Hygiene Supervision of Cosmetics.

Info SINO: The CFDA keeps on updating an Inventory of Existing Cosmetic Ingredients in China, listing those allow in China. You want further information ? Check the following link: China IECIC – Inventory of Existing Cosmetic Ingredients in China (2015)

Cosmetics that contain new ingredient require separate pre-approval from the CFDA before it can be introduced in cosmetic products destined for the Chinese market.

1.2 Exemptions for the Application of Pre-market Approval License

All cosmetics have to be made record keeping or approved with CFDA before being placed in the Chinese market. However, it is not required for soaps, toothpaste and oral cleaner. Indeed, those products can be imported into China directly after custom clearance.

2/ How to get CFDA approval license for your cosmetics products in China?

2.1 Appointing a Chinese responsible agent

An overseas company must appoint a Chinese agent to apply to the CFDA license in a written Power of Attorney. Indeed, the company cannot register its cosmetic products itself. The Chinese responsible agent can be whether a Chinese subsidiary company, a distributor or a third party (a consulting firm for example). It is essential that you should consider pros and cons before choosing your agent.

PROS CONS
Chinese subsidiary company No risk for you

Convenient: Easiest way for customs clearance when you have several distributors as a foreign company.

Expensive: Creation of a new subsidiary in China is expensive.

– TIME: The product registration can only start after the subsidiary’s registration.

Distributor Cost savings: The distributor can help you to deal with the pre-market registration. Problem of ownership: If the distributor pays the cost of registration, you would not be the owner of the approval license fore sure.

Not convenient: It may be hard to change the distributor.

Problem of privacy: you will have to give confidential information to the distributor.

Third party Ownership: You will be the owner of approval license.

Time savings

Unequal level: it may be difficult for you to find a consulting firm with high-qualified and professional services.

Info SINO: The Chinese agent is only responsible for the product registration, not for product safety. Moreover, their names have not to appear on any product label.

Warning SINO: A foreign manufacturer has only one responsible agent in China. However, different foreign manufacturers can have the same responsible agent in China to apply for the CFDA license.

2.2 Application of User Name and Password

After having been appointed, the Chinese responsible agent has to apply for a username and password to access CFDA’s online registration system before registering cosmetic products. Furthermore, to apply for a username and password, you have to provide CFDA with a notarized appointment letter and the business license of the agent.

Info SINO: The procedure should take you about one month.

2.3 Product Formula

It is advised to have the product formula reviewed before submitting registrations to CFDA. Product formula contains details such as the International Nomenclature of Cosmetics Ingredients (INCI) name, standard Chinese name, concentration and function of each ingredient.

The product will not be approved by CFDA if it contains prohibited ingredients or if it does not meet the requirements of restrictive conditions in Hygienic Standard for Cosmetics (2016). 

If the product contains a new cosmetic ingredient not registered in the Inventory of Existing Cosmetic Ingredients in China, the new element will also need CFDA’s approval as mentioned above.

2.4 Labelling of cosmetics

If you want to import cosmetic products into China, you have to make sure that they are labelled according to the mandatory National Standard GB 5296.3-2008 – Instruction for use of consumer products – general labelling for cosmetics.import cosmetics china

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 licence, product standard or administrative approval code
  • Safety marks and product literature

*In case of imported cosmetics, the country of origin, the name and address of the distributor in China shall be identified on the label.

When it comes to claiming on the package that your products has therapeutic effects using absolute words such as top-level, anti-bacterial, stem cells, growth factor, it is highly prohibited by CFDA.

SINO Advice: It is highly recommended to make the product package reviewed before submitting any registrations to CFDA.

2.5 Testing requirements

Cosmetics need to be tested in CFDA-designated laboratories in China during the registration process even if they have already been tested abroad.

For all cosmetics, hygiene safety tests are mandatory. The CFDA has authorized 21 laboratories to perform hygiene safety tests that consist in physio-chemical, microbiological and toxicological studies.

For special cosmetic use, human safety tests are also required, and 6 laboratories are authorized to conduct this type of tests.

Additional tests are needed if a cosmetic product contains risk substances.

If a cosmetic product contains risk substances, that is to say impurities or additives that may cause potential harm to human health due to raw materials or materials brought in during the production process, then, additional tests are required.

2.6 Registration dossier depending on the nature of cosmetics products you want to import

Depending on whether you apply for a New Cosmetic Ingredient, Cosmetic for specific or not specific use, the application is a bit different.

FOR NEW COSMETIC INGREDIENT

1. Application form for hygiene licence for new cosmetic ingredient.
2. A research & development report consisting of the following information:

R&D process and relevant technical files

Ingredient’s source, physio-chemical properties and molecular structure and weight

The purpose of using the ingredient, supporting proof, the range of concentration and limits on volume, announcements and warning words.

Statements on the use of the ingredient in other countries

3. Brief introduction to manufacturing process and flow chart.
4. Applying product standards and codes for quality and safety control of ingredient (including test method, specifications, potential safety risk substances and relevant measures of control).
5. Toxicology safety assessment data (including the assessment review, required toxicology experiments materials and safety assessment materials for potential safety risk substances)
6. Power of attorney between manufacturer and agent – (the authorisation letter needs to be translated into Chinese and notarized by the native notary office and Chinese notarisation agent), copy of the agent’s business licence.
7. Statement from manufacturer guaranteeing that materials used meet the requirements of BSE free regions.
8. Documents proving that the manufacturer is allowed to produce/ sell cosmetics in the country of origin. Plus, the certification of the manufacturer quality assurance system or Good Manufacturing Practice and inspection report should be also submitted.
9. Other relevant information, which can support the application.

FOR SPECIFIC USE

1. Application form for the cosmetic product to be imported.
2. Product ingredients translated into Chinese.
3. Product formula provided in both Chinese and English.
4. Brief introduction to manufacturing process and flow chart.
5. Applying product quality and safety standards – Cosmetics manufacturer can list international standards. As a minimum the international standard must not have lower requirements than the applying Chinese standard.

If using Chinese standards, list the specific standards used, including testing limits and methods.

6. Original product packaging including labelling information following requirement set out in GB 5296.3-2008.
7. Copy of approved test report from the designated laboratory.
8. For Special Use Cosmetics using functional components, such as sliming aids, hair nourishing, breast enhancements, etc. the manufacturer should provide the clinical study.
9. Power of attorney between manufacturer and agent – (the authorisation letter needs to be translated into Chinese and notarized by the native notary office and Chinese notarisation agent), copy of the agent’s business licence.
10. Statement from manufacturer guaranteeing that materials used meet the requirements of BSE free regions.
11. Documents proving that the manufacturer is allowed to produce/ sell cosmetics in the country of origin.

In addition, the certification of the manufacturer quality assurance system or Good Manufacturing Practice inspection report should be also submitted (if applicable).

12. Other relevant information, which can support the application.

NON-SPECIAL USE COSMETICS

1. Application form for the cosmetic product to be imported.
2. Product ingredients translated into Chinese.
3. Product formula provided in both Chinese and English.
4. Applying product quality and safety standards – Cosmetics manufacturer can list international standards.
5. Product quality control  (description of internal control mechanisms put in place by the manufacturer to guarantee quality of raw material, compliance with adopted standards, etc.)
6. Original product packaging including labelling information following requirement set out in GB 5296.3-2008.
7. Copy of approved test report from the designated laboratory.
8. Power of attorney between manufacturer and agent – (the authorisation letter needs to be translated into Chinese and notarized by a Chinese notarisation agent), copy of the agent’s business licence.
9. Statement from manufacturer guaranteeing that materials used meet the requirements of BSE free regions.
10. Documents proving that the manufacturer is allowed to produce/ sell cosmetics in the country of origin.

In addition, the certification of the manufacturer quality assurance system or Good Manufacturing Practice (GMP) inspection report should be also submitted (if applicable).

11. Other relevant information, which can support the application.

2.7 CFDA review

CFDA conducts review that is split into 2 steps:

  • A format review or completeness check that should take 5 working days
  • A technical review that should take about 3 months

Info SINO: The CFDA holds a meeting once a month to conduct the technical review of the registration of special use cosmetics.

After the application’s approval, the CFDA issues a certificate that will be requested for customs clearance. The certificate number must be displayed on the Chinese label of the cosmetic products.

The procedure’s duration to register products and registration costs depend on the nature of the cosmetics you wan to import. Here is a recap chart:

Non-special use cosmetics Special use cosmetics
Procedure’s duration 6 – 8 months  12 000 – 18 000 CNY
Registration costs * 9 – 14 months 19 000 – 80 000 CNY

*The registration costs include testing fee and consulting fee but exclude extra test fees. Moreover, the CFDA does not charge any administration fee.

2.8 CFDA Evaluation

The CDFA will brief you within 5 days confirming whether your application is accepted or not.

Info SINO: If your application is not accepted, the CFDA will give you explanation of discrepancies or missing documentation in order that you may be able to make another application.

After your application has been accepted by the CFDA, your Chinese responsible agent is likely to be contacted for clarifications or any technical questions that may have arisen during the review.

Furthermore, make sure that any changes made to the approved cosmetic product should be notified to the CFDA following the applying regulations. This concerns changes in the labelling information as well as in the product ingredients.

SINO Advice: Application for renewal of CFDA approval should be applied in advance in order to avoid any disruptions.

3/ Customs Clearance

*After having received CFDA approval license, foreign manufacturers are now qualified to export their cosmetics to China.

When the goods arrive at Chinese ports, the importer has to apply for an inspection from the local branch of the China Inspection and Quarantine Bureau (port CIQ).

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

  • The copy of the license
  • The product formula
  • A compliance declaration
  • Sample page of Chinese label
  • Original label and translation version

For its part, the port CIQ will:

  • Do a random sample check and conduct physio-chemical and microbiological tests
  • Review the Chinese label according to GB 5296.3-2008.

If the goods pass CIQ’s inspections, the port CIQ will issue a certificate of inspection which is then used by importers for clearing customs.

Remark SINO: This article is for informational purposes only. Please contact us to learn more about the importation of cosmetics and their classification. We are an experienced forwarder, specialized in import-export in China and Hong Kong. We have built a strong expertise over the past decade, ensuring prompt and efficient shipments.

Through our offices and our staff in China, we work hand-in-hand with our customers, their suppliers and the relevant official institutes to ensure a safe and hassle-free transportation from China to the rest of the world.

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