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Guide

Do travel-size or gift-set cosmetics need their own China filing?

Travel-size products and gift sets do not enjoy a blanket exemption from China filing or registration. A smaller net content of the same cosmetic, using the same Chinese name, formula and responsible parties, may be handled as another specification of the same product when the system and labelling rules allow that. A travel SKU with a new Chinese name, a changed formula or unique claims is generally a new filing or registration. Gift sets are discussed further in multi-product gift sets.

How to judge the path

Do not assume that “not for individual sale” printed on a minis bottle removes the need for the contained cosmetics to have records if they are placed on the market.

SPF travel minis remain sunscreens and must be registered; they cannot borrow an ordinary moisturizer filing.

Typical documents, tests and labels

Compare the Chinese name, formula, net content presentation and claims with the existing file before you ship a minis program. 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

Airline sets assembled only for export out of China are outside this page’s focus. This page concerns placing products on the China mainland market.

Questions we are often asked

Can I use a sticker to change 50 ml to 15 ml on the same filing?

Net-content changes must remain truthful and consistent with the filed specifications. Follow the labelling rules and any specification-update process then in force rather than covering an old number.

Does a holiday flavour of the same cleanser need a new filing?

If fragrance or other formula ingredients change, it is a different product unless a current similar-formula rule applies to the way you present it. A new Chinese name also typically needs its own file.

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.

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