Can I export sunscreen spray, stick or milk to China under the same path as a lotion?

Q: Can I export sunscreen spray, stick or milk to China under the same path as a lotion?

Yes. A sunscreen spray, stick or milk follows the same special-cosmetics registration path as a sunscreen lotion. The Cosmetics Supervision and Administration Regulation turns on the sun-protection function, not on whether the texture is a lotion, milk, stick or spray. None of these forms may use ordinary filing or the about 10–20 day ordinary-filing cycle.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

Classify the dosage form correctly. The classification catalogue distinguishes sprays without propellant from aerosols that contain propellant. That choice affects coding, packaging and transport information, but not the fact of registration.

Application site still matters. Hair is not an action site for sunscreen under the classification rules. Lip, face and body sites should be coded as claimed.

Typical documents, tests and labels

Complete sunscreen evaluations appropriate to the product that will be sold, including SPF or PA and any water-resistant claim. 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.

Aerosol packaging may need extra safety and packaging information in the dossier. 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 assume one registered lotion automatically covers a later spray or stick with a different formula or Chinese name. Those are usually different products.

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.

Questions we are often asked

Can one SPF study cover both a spray and a cream?

Only where the rules on similar-formula products and shared data, including Announcement No. 70 of 2026 where it applies, actually allow it. Different dosage forms are not automatically the same product.

Are continuous-spray sunscreens treated as cosmetics?

If they are applied to skin for sun protection and otherwise meet the cosmetic definition, they are sunscreen special cosmetics. Follow aerosol or spray classification and the technical standards.