Julie Harrington of CIRS details how to stay compliant when importing perfume and makeup products into China
Importing into China : What you need to know
Julie Harrington of CIRS details how to stay compliant when importing perfume and makeup products into China
Perfume and makeup products are two of the most widely imported cosmetic products to China from the EU and the US . They are considered to be cosmetic products in China because they meet the definition of a cosmetic according to the overarching Cosmetic Supervision & Administration Regulation ( CSAR ), implemented in 2021 by the National Medical Products Administration ( NMPA ).
The CSAR defines cosmetics as daily chemical industrial products that are applied to skin , hair , nails , lips and other human surfaces by scrubbing , spraying or other similar methods for the purpose of cleansing , protecting , beautifying and modifying .
The management process for importing perfume and makeup products is determined by their classification in China ( Figure 1 ). In general , these products are classified as ‘ ordinary cosmetics ’ but certain claims , such as sun protection factor ( SPF ) or use on children and infants may result in a special classification .
Perfume and makeup products without special claims are considered ordinary cosmetics and are subject to filing management . Those with special claims require registration management .
An important consideration for overseas companies based in the EU is whether they have a legal entity based in mainland China or a domestic responsible person ( DRP ). This is a mandatory requirement of the CSAR . The DRP should be a registered legal entity in mainland
China and have a business licence in the scope of cosmetics and relating to import and export .
Filing & registration in China
Figure 2 shows the standard process for the filing and registration of cosmetic products in China . For perfume and makeup products without special claims , i . e . ordinary cosmetics , animal testing requirements in China may be waived under certain conditions :
• The product is classified as an ordinary cosmetic .
• A GMP certificate has been issued by the government of the country of origin
• A safety assessment report verifies the safety of the product
• There are no claims for use by infants and children
Figure 1 – Classification of cosmetic products in China
Special Ordinary Other
Hair dye
Hair perm Toothpaste
Freckle-removing
Sunscreens
Cosmetics that are not cosmetics
Anti-hair loss Soap ( without a special claim )
Products with new efficacy
Products with new efficacy refer to cosmetics with efficacies and application methods not listed in the Classification Rules & Catalogue , as well as cosmetics targeted at children , pregnant women , and breastfeeding women .
54 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981