Filing vs registration: what is the difference

Under China’s current cosmetics rules, ordinary cosmetics are subject to filing administration and special cosmetics are subject to registration administration. Filing is completed when the required materials are submitted through the official information service platform. Registration requires review and a registration certificate before manufacture or import. Choosing the wrong path means the timeline, tests and dossier will not match the product.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

Special cosmetics are products used for hair dyeing, perming, spot-removal or whitening, sun protection or preventing hair loss, and products that claim a new efficacy as provided in the rules. Everything else is an ordinary cosmetic. Judge from the formula, method of use and claims, not from a brand name that sounds mild or luxurious.

Imported products use the same classification. An imported moisturizer is still filed if it is an ordinary cosmetic; an imported sunscreen is still registered.

What to prepare

Both paths share a basic dossier structure: applicant information, manufacturer information, name, formula or full ingredients, product standard, label artwork, test reports and safety-assessment materials. Special cosmetics add category-specific safety or efficacy studies and generally require a full safety-assessment report. Ordinary cosmetics may, where the classified submission rules allow, submit a basic safety-assessment conclusion while keeping the full report on file.

Cautions

Do not apply the ordinary-filing cycle of about 10–20 days to special cosmetics. The registration periods we publish are review times after testing is finished. Details are in how long filing or registration takes.

Questions we are often asked

Is filing just a quicker form of registration?

No. They are different legal procedures with different legal effects. Filing is not a lighter registration certificate.

What if marketing wants both “SPF” and “whitening”?

Both claims sit inside special cosmetics. Prepare the product as a special cosmetic that covers both claims, rather than filing it as an ordinary product.