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Guide

How do I export an eyeshadow or contour palette to China?

An eyeshadow or contour palette can be exported to China as ordinary color cosmetics when the pans are used to temporarily modify appearance. Do not assume the whole palette is a single formula. Shades with different colorants are different products, even when they sit in one compact. Announcement No. 70 of 2026 allows a registrant or filer to share specified safety or efficacy data across certain similar-formula products that differ mainly in colorants and a defined list of other ingredients, after an explanation and equivalence assessment. That does not mean unnamed extra pans can be sold without being identified.

How to judge the path

Eye-area shades must use colorants permitted for the eye area. Contour palettes used on the face should not quietly include an SPF “finishing” shade without sunscreen registration.

A palette that mixes separately usable formulas is different from two components that must be used together and cannot be split.

Typical documents, tests and labels

Plan filings or shared-data packages shade by shade, then label the compact so consumers can identify what they are buying. 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. 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

Refill pans sold later under new names are easy to treat as afterthoughts; they still have to match a filed or registered product.

Questions we are often asked

Can I file only the palette name and list “various colours”?

The dossier still needs the actual shade formulas you will sell. A decorative palette name is not a substitute for identifying each product.

Does adding a mirror or brush create a new cosmetic?

The mirror or brush is not itself a cosmetic. The cosmetic products in the palette remain the items that must be filed or registered.

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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