Can cushion foundation be exported to China?

Q: Can cushion foundation be exported to China?

Yes. Cushion foundation can be exported to China as an ordinary cosmetic when it is used to temporarily modify appearance and does not claim sun protection or whitening. The cushion sponge and compact are part of the product presentation, but the cosmetic that must be filed is the foundation formula you will sell, including refill versions that have their own names or formulas. A cushion with SPF must be registered as a sunscreen.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

Refills should not be treated as unregulated spare parts if they are separately sold cosmetics. A refill with a different formula or Chinese name is a different product.

Tone-up cushions often sit close to whitening language; read the Chinese claims carefully.

Typical documents, tests and labels

If the cushion remains ordinary, Testing and ordinary cosmetics filing may proceed in parallel. The ordinary filing cycle is about 10–20 days in total, depending on completeness and supplementary requests. That timing applies only to ordinary cosmetics filing, never to special cosmetics registration and not as a guaranteed import timeline. 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. 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

Do not file only the compact case. The dossier has to describe the actual foundation, shades and replaceable inserts you intend to place on the market.

Questions we are often asked

Is the puff itself filed?

The puff is usually part of the sales unit rather than a separate cosmetic, unless you sell a treated puff as its own cosmetic product.

Can a cushion with SPF share data with a bottled foundation?

Only if they qualify under current similar-formula and shared-data rules. Different dosage forms are not automatically equivalent, and any SPF version must be registered.