If a shampoo deposits color on hair, is it filed or registered in China?

Q: If a shampoo deposits color on hair, is it filed or registered in China?

If a shampoo is used to change hair colour and immediate washing does not restore the original colour, it is assessed as a hair-dye special cosmetic and must be registered. Calling it a shampoo, gloss or colour-refresh wash does not keep it on ordinary filing. A shampoo that only cleans hair, or that only helps maintain an already dyed colour without itself changing colour, may remain an ordinary cosmetic.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

The classification rules define hair dye by purpose and by whether immediate washing restores the original colour. Gradual colour-depositing shampoos usually meet that definition.

Ordinary colour-care claims are narrower: they help keep an existing colour stable and are not themselves a colour-changing function.

Typical documents, tests and labels

If it is hair dye, use permitted colorants and prepare a registration dossier. For hair-dye registration, oxidative testing is about 50 working days and non-oxidative testing about 35 working days; review is about 8 months after testing is finished. Actual time depends on completeness and supplementary requests. Do not use the about 10–20 day ordinary-filing cycle.

Announcement No. 70 of 2026 describes a toxicology-report waiver only for non-oxidative hair-dye products that meet its stated conditions. Apply it as written. 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

For general-trade import of a finished product, complete the required filing or registration before import, appoint a Domestic Responsible Person, and apply a Chinese label that meets the Cosmetics Labeling Rules. Customs and inspection-quarantine formalities are a separate process. Cross-border e-commerce retail import is a different channel with list, platform and personal-use limits; it is not a blanket “no filing” rule and not a path to unrestricted domestic resale.

Do not file the wash as ordinary shampoo while the label still promises a visible new colour.

Questions we are often asked

What about a coloured bottle that does not stain hair?

If the product does not change hair colour, it is not hair dye merely because the liquid is coloured. The function and the result on hair decide the path.

Are root-touch-up mascaras treated the same way?

If they are used to change hair colour and the colour does not wash out immediately, assess them as hair dye even if the format looks like makeup.