Home / Guides / Can a makeup primer with SPF be exported to China as ordinary cosmetics?
Guide
Can a makeup primer with SPF be exported to China as ordinary cosmetics?
No. A makeup primer with SPF cannot be exported to China as an ordinary cosmetic. Sun-protection use or an SPF claim makes it a sunscreen special cosmetic, even if the primary marketing story is makeup grip or pore-blurring. Ordinary primers without a sun-protection function are usually filed as ordinary beauty-modification cosmetics.
How to judge the path
The dosage form name—primer, base, makeup milk—does not decide the path. The SPF number does.
If the primer also claims whitening, prepare both special-function packages.
Typical documents, tests and labels
Register the product as a sunscreen. For sunscreen registration, toxicology testing is about 35 working days, SPF and PA evaluations are about 30 working days each, and review is about 10–12 months after testing is finished. Actual time depends on completeness and supplementary requests. Do not use the about 10–20 day ordinary-filing cycle. 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 the primer as ordinary makeup and print SPF only in small letters on the overseas carton.
Questions we are often asked
Is a “light protection” primer without a number still a sunscreen?
If the wording communicates sun protection or the formula is used to protect against specified ultraviolet damage, assess it as a sunscreen special cosmetic.
Can I sell the SPF and non-SPF primers under one filing?
No. They are different products with different functions. The non-SPF version may be an ordinary cosmetic; the SPF version must be 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.
Contact us