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How to import cosmetic products in China: regulatory aspects

In 2021, China imported RMB 161.3 billion (€ 22.34 billion) of cosmetic products, with an increase of 23% compared to 2020. The main importers of these products in the Chinese market are Japan, South Korea, France and the United States.

On January 1, 2021, the "Cosmetic Supervision and Administration Regulation (CSAR)" came into force which replaced the "Cosmetic Hygienic Supervision Regulation" in force since 1990. This regulation concerns: the definition and classification of cosmetics, new ingredients, the issue of cosmetic production and import licenses and the quality control and safety assessment of cosmetic products.

Central is the role of the National Medical Products Administration (NMPA) which approves the new ingredients and issues the related licenses.

The new regulation also requires foreign companies to appoint a qualified legal representative in China to manage the registration process and safety and quality aspects of cosmetic products. This representative must have no less than 5 years of experience in the field of cosmetics.

On May 1, 2021, the "Administrative Provisions of Cosmetics Registration and Filing of the China National Medical Products Administration (NMPA)" came into force which abolished the obligation to carry out tests on animals for cosmetic products defined "for general use ”(For example mascara, lipstick, shampoo, perfume, toothpaste and nail polish). However, this obligation remains in force for cosmetic products for special use (for example hair dyes, products to eliminate freckles, sun creams, products for hair loss). In replacement of the aforementioned obligation, a foreign company wishing to export cosmetic products to China will have to produce a Free Sale Certificate and the “Good Manufacturing Practice Declaration” (GMP). In Italy these documents are issued by the Ministry of Health.

Finally, from May 1, 2022, the “Administrative Measures on Cosmetics Labeling (NMPA)” came into force. Companies that have already registered and files their information for sale in China will have to proceed with updating the labels by May 1, 2023.

Avv. Lifang Dong and Avv. Chiara Civitelli

The content of this article does not constitute legal advice, but has an informative function. For tailor made legal advice, contact the firm by e-mail to: or by phone +39 06 916505710. © Dong & Partners International Law Firm, All rights reserved.

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