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Guide
Are hair bleach or lightening products registered like hair dye in China?
Hair bleach and hair-lightening products are generally registered like hair dye in China when they are used to change hair colour by lightening it and immediate washing does not restore the original colour. The classification rules describe hair dye as a function of changing hair colour, not only of adding a darker shade. These products are not ordinary bleach-for-laundry items and they are not ordinary conditioners.
How to judge the path
Oxidative lightening systems and bleach powders used on hair should be assessed as hair-dye special cosmetics, together with any developer that forms part of a combined product that must be used together.
A product that only claims to brighten an already coloured tone without changing hair colour should be reviewed carefully against its actual effect; do not assume a “brightening oil” avoids dye classification if it lightens hair.
Typical documents, tests and labels
Prepare a hair-dye registration dossier and use only substances allowed for that use in the Safety and Technical Standards for Cosmetics. 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.
Combined kits that must be used together are classified as one product under the classification rules. 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
Highlighting kits sold for the China market still need the correct special-cosmetics registration. Professional salon positioning does not remove that duty.
Follow the rules and system requirements in force at the time of submission if a specific bleach format is hard to map; do not treat uncertainty as ordinary filing.
Questions we are often asked
Is hydrogen peroxide developer itself a hair dye?
A developer supplied as part of a hair-lightening or dyeing system is assessed with that system. A standalone oxidizing cream should be classified according to its intended cosmetic use and the technical standards.
Can I file bleach as ordinary “hair care” if I avoid the word dye?
No. Changing hair colour by bleaching is a hair-dye function even if the marketing name says brightening, clarifying or highlight care.
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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