What is required to register a sunscreen for the China market?

To register a sunscreen for the China mainland market, treat it as a special cosmetic used for sun protection. You generally need a registration dossier, a safety assessment, evidence that the UV filters are permitted and used within the Safety and Technical Standards for Cosmetics, the required toxicology and SPF or PA evaluations, a Chinese label that matches the file, and—if the product is imported—a Domestic Responsible Person plus the usual overseas documents. 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.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

Confirm that the product is actually a sunscreen: it is used to protect skin or lips from specified ultraviolet damage, or it bears SPF, PA, broad-spectrum or water-resistant sun-protection claims.

Identify the application site, user group and dosage form. Body, sport, facial, lip and children’s sunscreens share the special-cosmetics path, but classification coding, warnings and extra children’s rules differ.

If whitening is also claimed, the product remains a special cosmetic and both claim packages must be prepared.

Typical documents, tests and labels

Typical materials include formula and ingredient quality information, manufacturing process, product standard, package artwork, Chinese labelling text, safety assessment, toxicology, SPF and PA studies, and any water-resistant study if that claim is made.

Imported finished goods also need relationship documents, original packaging or an accepted substitute, and marketing proof unless a current first-launch commitment under Announcement No. 70 of 2026 applies. 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

Registration review time starts after testing is finished. Supplementary requests reset practical calendars, so completeness matters more than a promised date.

Do not file a sunscreen as an ordinary cosmetic even if the SPF is low or the product is marketed as a moisturizer or makeup item.

Questions we are often asked

Is water-resistance testing always required?

Only when you make a water-resistant or waterproof sun-protection claim. If you claim it, prepare the corresponding evaluation with the SPF work.

Can partner laboratory reports be used?

Yes. Testing is coordinated with partner laboratories, and the laboratory that performs a test issues that report. Jinshang Testing organizes the registration work around those reports.