Regulated cargo / 08

Cosmetics

Registration and filing requirements before the goods can be sold.

A consignment of cosmetics, with the packaging it travels in
  1. 01

    Registration or filing is complete

    It runs in months, ahead of the shipment rather than alongside it.

  2. 02

    Every ingredient is permitted

    An ingredient allowed at home may not be allowed here.

  3. 03

    Labelling matches the filing

    Including the claims made on pack.

Cosmetics packed and sealed for the journey

The route

How a consignment moves

  1. 01

    Establish the product type

    Registration and filing are different routes with different evidence.

  2. 02

    Check ingredients against Chinese rules

    Before the formulation is committed. This is a formulation problem, not a customs one.

  3. 03

    Complete registration or filing

    Months, and before the shipment rather than alongside it.

  4. 04

    Confirm any additional requirements

    Products for children, and special-purpose claims, carry more. A whole-family claim on an adult product moves it into the children’s regime on its own.

  5. 05

    Assemble the ingredient evidence yourself

    Since May 2025 the historical maximum use levels in the older inventory can no longer carry a safety assessment. The registrant or filer is the first responsible party, so the file rests on supplier data and audits.

  6. 06

    Prepare Chinese labelling

    Consistent with what was registered, claims included. Some items belong on the display face and others on any visible face, and the filing number cannot be laid out before it exists.

  7. 07

    Declare, inspect, release

    To the distributor.

What we do

We map the import route against the product type, ingredients, registration or filing status and labelling, then coordinate the regulatory and customs work with the appropriately qualified parties.

Discuss a shipment

What you need

Documents

  • Registration certificate or filing record
  • Full ingredient list with function and concentration
  • Product safety assessment
  • Manufacturing licence and certificate of free sale
  • Chinese label artwork and original label translation
  • Invoice, packing list, transport document
  • Ingredient source documentation, by origin type
  • Supplier audit records for ingredient suppliers
  • Heavy metal and microbiological test reports
Storage and handling environment for cosmetics

Where it goes wrong

  1. This is a regulatory step, not a customs one.

    Treating registration as something to handle at the end is the common planning error here.

  2. An ingredient cannot be fixed at the border.

    Where it is not permitted, the decision is a formulation or product-selection one on your side.

  3. Claims are checked against the filing.

    What the pack says has to match what was registered.

Questions

How long before we can start selling?

Registration or filing is measured in months, and it runs before the shipment rather than alongside it. The most common planning error in this category is treating it as a customs step at the end rather than a regulatory step at the beginning.

One of our ingredients may not be permitted in China. What are the options?

This is checked against the ingredient rules before anything ships. Where an ingredient is not permitted, the answer is a formulation or product-selection decision on your side; it is not something that can be resolved at the border.

Are children’s products treated differently?

Yes, and the category is wider than most brands expect. It covers products for children aged twelve and under, but also any product labelled as suitable for the whole family, any colour cosmetic marketed for family use, and anything stating it can be used by children. The category follows the claim rather than the intended customer, so inclusive marketing copy can move an adult product into the children’s regime without a formulation change. Children’s sun protection products are special cosmetics needing a registration certificate; the little gold shield mark and an adult-supervision warning are required; and food-related presentation — food grade, edible, food imagery — is prohibited.

Does our Chinese distributor still need a cosmetics consignee filing?

No. That filing was abolished with effect from 1 January 2022. The domestic consignee now needs only the ordinary customs consignor and consignee filing. It is worth checking your process against this, because it is a step many plans still include.

Our ingredient safety data comes from the supplier’s filed information. Is that still enough?

Worth re-examining. Since 1 May 2025 the historical maximum use levels in the 2021 inventory can no longer serve as the basis for a safety assessment, so recommended addition levels bound to older ingredient codes have lapsed. The registrant or filer is the first responsible party and is expected to hold the substantive documentation — source evidence appropriate to the ingredient type, and audit records for the supplier who provided it.

Further reading

  1. Cosmetic ingredients for China run on a whitelist — and the old usage data expired in May 2025

    Historical maximum use levels from the 2021 inventory can no longer support a safety assessment. Filings built on ingredient codes rather than on real supplier data are the ones now exposed.

  2. Chinese cosmetic labels: the display face, the visible face, and the “family use” trap

    Some items must appear on the face the customer sees on the shelf, others merely somewhere visible. And a colour cosmetic marketed for the whole family is regulated as a children’s product.

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