Appointing a Domestic Responsible Person

An overseas cosmetics registrant or filer appoints an enterprise legal person in China as the Domestic Responsible Person. The appointment is made so that registration or filing can be handled in China and so that quality and safety duties can be performed there. The responsible person must be able to carry out those duties. Lending a company name or a warehouse address is not enough.

Published 11 November 2026 · Updated 11 November 2026

How to judge whom to appoint

Choose a Chinese enterprise legal person that can submit and maintain information on the official platform, assist with adverse-reaction monitoring and recalls, cooperate with supervision, and take the corresponding quality and safety responsibility agreed with the overseas company. That company may be your subsidiary or another authorized entity. A natural person cannot fill the role.

What to prepare

Prepare an authorization that clearly identifies the overseas registrant or filer and the Domestic Responsible Person and describes the scope of the appointment. Notarization or other formalities should follow the requirements then in force. If you later change the responsible person, NMPA Announcement No. 70 of 2026 no longer asks for a stamped consent letter from the previous responsible person or a court judgment; the focus is a notarized authorization, a product list and a commitment by the new responsible person covering products already on the market. Use the announcement text and current system prompts when you prepare a change.

Cautions

If the responsible person’s address changes in a way that changes the administering authority, re-filing may be required. If imported ordinary cosmetics will enter through a port outside the responsible person’s province, supplement the port information on the platform. Jinshang Testing can help compile documents but does not become the Domestic Responsible Person by writing a dossier.

Questions we are often asked

Can one responsible person cover several imported brands?

A company may be authorized by more than one overseas brand if each authorization is clear and the company can actually perform the duties for those products. Overloading a nominee company undermines the legal purpose of the role.

Is this the same as an EU Responsible Person?

No. The EU Responsible Person and China’s Domestic Responsible Person arise under different laws and are not interchangeable.