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Guide
Imported vs China-made: which compliance path applies
Imported and China-made cosmetics both have to follow ordinary filing or special registration according to what the product is. The difference is not that one path is reviewed and the other is not. It lies in who files or registers, which authority administers ordinary filing, which overseas documents are needed, and how the manufacturer and Domestic Responsible Person appear on the Chinese label.
How to judge the path
If the last process in contact with the bulk is completed outside mainland China and the finished product will be imported, treat it as an imported product. If a licensed mainland factory produces the product in China, treat it as a China-made product even if the brand owner is overseas. Changing only the shipping carton does not turn an imported formula into a domestic product.
Imported ordinary cosmetics are filed before import; domestic ordinary cosmetics are filed before they are placed on the market, with the provincial authority where the filer is located. Special cosmetics, imported or domestic, are registered.
What to prepare
Both paths need the basic dossier: identity of the filer or registrant, manufacturer information, name, formula, product standard, label artwork, test reports and safety-assessment materials. Imported products usually also need overseas marketing evidence (unless an exception applies), original sales packaging and a Chinese translation, and a Domestic Responsible Person. Domestic contract manufacturing requires platform confirmation of the manufacturing relationship and the factory’s production-licence information.
Cautions
The 10–20 day cycle we use for ordinary cosmetics filing, where testing and filing proceed in parallel, is the domestic ordinary-filing description. Import projects often take longer because of translations, overseas documents and the responsible-person arrangement. Special cosmetics never use that cycle.
Questions we are often asked
If we move production to China, can we keep the import filing number?
A change from overseas production to mainland production is a change of production site and dossier identity. NMPA Announcement No. 70 of 2026 allows some test and assessment reports to be reused when certain items stay the same, but microbiological and physicochemical tests generally need to be redone. Follow the announcement and current system rules; do not keep using an import number as if nothing changed.
Does “made in China” avoid special-cosmetics registration?
No. Classification follows the product’s use and claims, not the country of manufacture.
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