To sell a cosmetic product in mainland China, the China CSAR cosmetics regulation requires you to classify the product as either “special” or “general,” compile a technical dossier covering formula, safety, and efficacy, appoint a Domestic Responsible Person inside China, and file with the National Medical Products Administration (NMPA) before the first sale. Special cosmetics go through full registration and expert review; general cosmetics go through a faster notification. The Cosmetics Supervision and Administration Regulation took effect January 1, 2021 under State Council Decree No. 727, and it governs every product manufactured, imported, or sold on the mainland.1State Council of the People’s Republic of China. State Council Gazette Issue No 19 Serial No 1702
Classify the Product First
Classification decides your timeline, your budget, and the depth of evidence you will need to produce. CSAR sorts every cosmetic into one of two buckets.
Special cosmetics are the higher-risk category and cover five specific product types: hair dyes, hair perming products, whitening and freckle-removing products, sunscreens, and anti-hair-loss products.2National Medical Products Administration. Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics Any product that claims a new functional effect not already on that list is automatically pulled into the special category as well, so novel claims trigger the most intensive pathway by default.
General cosmetics cover everything else: moisturizers, cleansers, makeup, perfumes, body washes, and similar everyday items. These go through electronic notification rather than full registration, and the practical time difference is enormous. A general cosmetic notification can be processed quickly online. A special cosmetic registration typically runs 90 to 180 working days, longer if the initial dossier draws follow-up questions.
Children’s Cosmetics Have Extra Rules
If your product is marketed for children aged 12 and under, additional requirements apply on top of whichever category you land in. Since May 2022, all children’s cosmetics sold in China must display the “Little Golden Shield” logo on the upper left of the main display panel. The logo must be at least 2 centimeters wide on packages with a display area larger than 100 square centimeters, and at least 1 centimeter wide on smaller packages. Products not formulated for children may not use the logo.
Ingredient scrutiny is also stricter. Using a banned raw material or an unregistered new ingredient in a children’s product is treated as a serious violation and triggers the harshest penalty tier under CSAR.2National Medical Products Administration. Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics
Confirm Every Ingredient Is Approved
Every raw material in your formula must appear on the Inventory of Existing Cosmetic Ingredients, China’s approved substances list.3National Medical Products Administration. Announcement of the National Medical Products Administration on Matters Related to the Administration of the Inventory of Existing Cosmetic Ingredients Anything not on the Inventory is classified as a New Cosmetic Ingredient and cannot be used until it clears a separate approval pathway.
That pathway forks by risk level. Higher-risk new ingredients, including preservatives, UV filters, colorants, hair dyes, and whitening agents, require formal registration. Lower-risk new ingredients only require a notification filing. Once approved, the new ingredient enters a three-year safety monitoring period during which the introducing company must file annual safety reports covering real-world usage.3National Medical Products Administration. Announcement of the National Medical Products Administration on Matters Related to the Administration of the Inventory of Existing Cosmetic Ingredients If nothing concerning surfaces in three years, the ingredient is added to the Inventory and becomes available to any manufacturer.
Assemble the Dossier
Building the technical dossier is where most compliance time and budget goes, and a weak dossier is the most common reason filings stall.
Formula and Quality Documentation
Start with the complete product formula listing every ingredient and its concentration, plus quality control standards showing the manufacturing process produces consistent, safe batches. The original label and consumer-facing usage instructions also go into the package.
Efficacy Claim Substantiation
CSAR requires scientific evidence for every functional claim, summarized in an Efficacy Claim Substantiation document uploaded to a government-designated platform for public access. The evidence standard depends on the claim. Whitening, sun protection, anti-hair-loss, acne control, and repair claims require human efficacy trials conducted by NMPA-accredited testing institutions inside China. Basic claims such as moisturizing can rely on literature reviews, laboratory data, or consumer perception studies.
Safety Assessment Report
A Safety Assessment Report analyzes the toxicological profile of the finished product and each ingredient, and calculates margins of safety against realistic consumer exposure. It must be prepared and signed by a qualified safety assessor who holds expertise in medicine, pharmacy, biology, chemistry, or toxicology, with at least five years of hands-on experience in cosmetic safety or ingredient quality control. The assessor takes personal responsibility for the scientific accuracy of the report. Calculation methods, data sources, and exposure models must follow the NMPA’s Technical Guidelines for Cosmetic Safety Assessment.4National Medical Products Administration. The Provisions for Registration and Filing of Cosmetics
Safety assessment documents must be retained for at least ten years after the last marketed batch expires.
GMP Certificate for Imported General Cosmetics
Foreign manufacturers importing general cosmetics need a Good Manufacturing Practice certificate, or equivalent quality management certificate, from a recognized authority in their home country. It must be issued or approved by a competent government department, certification body, or accredited third party. This document also serves as one of the preconditions for the animal testing exemption discussed below.
Appoint a Domestic Responsible Person
Any foreign company using the standard registration or notification pathway must appoint a Domestic Responsible Person (DRP) based in mainland China. The DRP is the NMPA’s primary point of contact and carries real legal exposure. Its duties include:
- Submitting registration and notification applications on behalf of the foreign registrant
- Assisting with ongoing safety surveillance and reporting adverse reactions
- Facilitating recalls when safety issues emerge
- Responding to inspections and information requests from the NMPA and local regulators
- Assuming agreed safety and quality obligations for the products in the Chinese market
The DRP’s competence directly affects filing speed, regulatory relationships, and how quickly the brand can respond if something goes wrong after launch.
File with the NMPA
All filings run through the NMPA’s online portal. You create a corporate account, verify identity, select the product category, and upload the dossier. From there the paths diverge.
General cosmetic notifications are designed for speed. Once accepted, the system generates an electronic certificate that customs, retail partners, and the public can look up. Notification certificates remain valid indefinitely as long as the filed information stays accurate.
Special cosmetic registrations go to a technical expert panel that reviews the safety data, formula, and efficacy claims. This review typically takes 90 to 180 working days and often involves requests for supplemental information.5National Medical Products Administration. The Provisions for Registration and Filing of Cosmetics Registration certificates are valid for five years and must be renewed before expiration.
Get the Label Right
Every cosmetic sold on the mainland must carry a label in standard simplified Chinese. Other languages and symbols may appear on the packaging but need a corresponding Chinese explanation. The label must include:
- Product name in Chinese, plus the registration certificate number for special cosmetics
- Registrant or notifier name and address, or the DRP’s details for imported products
- Manufacturer name and address, plus a production license number for products made in China
- Product standard number
- Full ingredient list
- Net content
- Expiration date
- Usage instructions
- Safety warnings
- Any additional content required by other applicable laws or national standards
Label content must match exactly what was submitted during registration or notification. CSAR prohibits claims implying medical effect, false or misleading language, and content that violates public morals or Chinese law.2National Medical Products Administration. Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics General cosmetics may not use language suggesting they perform like a special cosmetic, and packaging cannot resemble food, drugs, or other non-cosmetic items.
Understand the Current Animal Testing Position
China’s approach has shifted meaningfully since CSAR took effect. Imported general cosmetics can qualify for an exemption from mandatory animal testing if two conditions are met: the manufacturer holds a valid GMP certificate from a recognized authority in its home country, and the product’s safety assessment fully confirms safety without animal data. Products marketed for infants or children, products containing new ingredients still within the three-year monitoring period, and companies flagged as key supervision targets by the NMPA do not qualify.
Special cosmetics historically faced stricter testing requirements. A December 2025 NMPA reform now allows companies to submit in-vitro and other internationally recognized non-animal testing methods conducted within China to satisfy toxicology requirements, including for new ingredients. The reform aims to align China’s framework with global standards and explicitly supports cruelty-free formulas. Practical implementation is still evolving, so verify acceptance of specific alternative methods with regulatory advisors in China before relying on them.
Consider Whether Cross-Border E-Commerce Fits Instead
Not every product entering China needs full CSAR registration or notification. Cosmetics sold through approved cross-border e-commerce (CBEC) channels are treated as personal-use imports and are exempt from the standard filing requirements. This has become a common entry route for foreign brands testing the market or selling niche items where full compliance does not yet make financial sense.
The trade-off is a different set of obligations. CBEC sellers bear primary responsibility for product quality and safety, must appoint a domestic entity for customs business registration, must maintain a product traceability system, and must share transaction data with customs. Product information and electronic labels must be posted on the sales platform so consumers can evaluate the product themselves. The CBEC route shifts the regulatory burden from pre-market filing to post-sale accountability; it does not remove it.
Plan for Post-Market Supervision and Penalties
Getting a certificate is the beginning of the compliance obligation, not the end. The registrant or notifier holds primary duty for product quality and safety throughout the product’s life. The NMPA and local regulators conduct random inspections and pull products from shelves for laboratory testing to confirm they match the filing. If actual composition or claims diverge from the paperwork, certificates can be revoked and sales halted.
Manufacturers must maintain a quality management system tracking every batch from raw material procurement through distribution, and be ready for unannounced inspections that may pull production records, ingredient sourcing logs, and batch testing results. Safety assessment documents stay on file for at least ten years after the last marketed batch expires.
Penalties under CSAR are considerably harsher than under the earlier framework. For serious violations, fines can be calculated as a multiple of the total value of the illegal products. The most severe tier applies to offenses such as using banned ingredients in children’s cosmetics, providing false information to regulators, refusing inspections, or committing repeat violations within one year of a prior penalty.2National Medical Products Administration. Provisions for Supervision and Administration of Manufacturing and Marketing of Cosmetics In the worst cases, individuals responsible for a company’s violations can face a lifetime ban from the cosmetics industry. Smaller fixed fines apply for administrative failures, such as up to RMB 30,000 for failing to update licensing information.
For a foreign brand, a revoked certificate does more than halt sales. It damages the relationship with the DRP, disrupts retail partnerships, and creates a public enforcement record visible to Chinese consumers and regulators. The cost of rebuilding trust after a serious action almost always exceeds the cost of doing the compliance work properly the first time.