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Common issues when exporting color cosmetics to China

Common issues when exporting color cosmetics to China include selling shades that were never filed, using colorants that are not permitted for the intended site, hiding an SPF claim inside BB cream or primer, and presenting a multi-shade palette as if it were a single formula. Ordinary makeup can often be filed, but each shade or independently used product still has to be handled under the current product and similar-formula rules.

How to judge the path

Eye-area and lip-area colorants have site-specific limits in the Safety and Technical Standards for Cosmetics. A colorant allowed in rinse-off body makeup is not automatically allowed in eyeliner.

Cushion refills, palette pans and gift shades are easy to forget in the dossier and then appear in e-commerce listings.

Typical documents, tests and labels

Complete ordinary filing or special registration before general-trade import, and keep listings aligned with the official file. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform. After a record is issued, check it on the official NMPA filing query https://hzpba.nmpa.gov.cn/gccx/ and the NMPA data-search page https://datasearch.nmpa.gov.cn/datasearch/home-index.html#category=hzp.

Cautions

Announcement No. 70 of 2026 allows certain similar-formula products that differ mainly in colorants and a short list of other ingredients to share specified test data when its conditions are met. That is a data-sharing rule, not permission to skip identifying each product.

Questions we are often asked

Why is SPF the most frequent surprise in makeup files?

Because primers, BB creams, cushions and setting sprays often carry SPF in the home market. In China those products are sunscreens and must be registered.

Can I file only the hero shade and sell the rest later?

You should not place unfiled shades on the general-trade market. Handle additional shades as their own products or under the similar-formula rules then in force.

Next step

Discuss your China market path

Tell us whether you plan to import finished goods or manufacture in mainland China, and what the product claims. We will outline the likely filing or registration path. Testing, where needed, is arranged with partner laboratories.

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