Exporting Cosmetics to China: Registration or Filing First. NMPA, Domestic Responsible Person, and CBEC

China is the biggest and most demanding market for K-beauty. Jumping in on population and buying power alone is a fast way to get stuck at regulation. China's cosmetics regime starts with two questions: is my product subject to registration or to filing, and who bears responsibility inside China. This guide covers the NMPA requirements a K-beauty brand must clear to export to China, from the product-type split to the CBEC route. To see where China sits among destination markets first, start with the cosmetics export overview.

The backbone of China's cosmetics regime: CSAR

China restructured its cosmetics system with CSAR (the Cosmetic Supervision and Administration Regulation), effective January 2021. The regulator is the NMPA (National Medical Products Administration). At its heart, CSAR splits products into two tracks by risk and requires a responsible party inside China.

Special vs general cosmetics: registration or filing

China divides cosmetics into special and general cosmetics. This split governs the entire entry process.

Special cosmetics need NMPA registration, a pre-market approval, before they can be sold. Sunscreens, hair dyes, whitening and freckle-removal functionals, perm products, and anti-hair-loss and new-efficacy products fall here. General cosmetics go by filing, a notification, and most skincare and color products are general cosmetics. Confirm which side your product is on first, because that sets the documents and the timeline.

The domestic responsible person: a required partner inside China

China requires an exporting brand to appoint a domestic responsible person inside China. This is a China-based entity that handles registration and filing, product release, adverse reaction monitoring, and recalls. A foreign brand cannot formally sell in China without this partner. Because the management of the registration dossier and your speed of response to the market shift with who this partner is, choosing a reliable one matters.

The animal testing exemption: open, but conditional

The biggest historical barrier to entering China was the animal testing required of imported cosmetics. Since May 2021, an animal testing exemption is open for general cosmetics, but with conditions.

Three preconditions must all be met: first, the product must be a general cosmetic; second, you must submit a GMP certificate issued by the government authority of the country of origin; and third, a safety assessment must confirm the product's safety. Products for infants and children, products using a new ingredient still within its monitoring period, and products from a notifier designated for key supervision are excluded from the exemption.

The practical stumbling block here is the GMP certificate. It can only be obtained if the country of origin has the relevant system in place, so the situation differs by country. Before exporting, confirm whether you can secure a GMP certificate for your product.

Efficacy evaluation: claims need evidence

CSAR requires a scientific basis for efficacy claims. In particular, functional claims such as whitening, freckle-removal, sunscreen, and anti-hair-loss must go through human efficacy testing conducted in China under national standards, and a summary of the efficacy basis must be published on the NMPA platform. Claims that are sensory-obvious, like cleansing, or explained by physical mechanisms, like physical exfoliation, are partly exempt from submitting an evidence summary. Because the tests and cost required depend on which claims you make, it helps to check the evidence requirements before locking your marketing language.

CBEC: the route that bypasses registration

A route every K-beauty exporter to China must know is CBEC (cross-border e-commerce). Selling directly to Chinese consumers through platforms such as Tmall Global or JD Worldwide is closer to personal import in nature, so it can bypass NMPA registration and filing, animal testing, and facility registration. By sharply cutting the time and cost of formal registration, CBEC is how many K-beauty brands first knock on the China market.

CBEC still has requirements: a Chinese e-label posted online, a China-based importer or agent to interface with the platform, customs declaration, and compliance with the ingredient positive list. And there is a decisive limit. CBEC is a direct-to-consumer route; to distribute formally through offline stores or general trade, you will ultimately need registration or filing. A staged strategy, validating the market via CBEC and then expanding into formal registration, is the realistic path.

Labeling and new ingredients

China requires Chinese-language labels, with the display items and format following its cosmetics labeling measures. If you use a new cosmetic ingredient, it must go through new-ingredient registration or filing, followed by a monitoring period. Because entry difficulty shifts with the ingredients, it helps to keep China's standards in mind from the raw-material stage.

A K-beauty China export checklist

• Split the product type: confirm whether it is a special cosmetic (registration) or a general cosmetic (filing).
• Appoint the domestic responsible person: a China-based partner to handle registration/filing, release, adverse reactions, and recalls.
• Check the animal testing exemption: general cosmetic plus a country-of-origin GMP certificate plus a safety assessment.
• Prepare efficacy evidence: whitening, sunscreen, and the like need in-China human testing and published evidence.
• Design the entry route: whether to validate via CBEC first or go straight to general-trade registration.

For a China export, customs and shipping only matter once the regulatory route is set. Prepare the HS code classification and export customs procedure together. The US (MoCRA) is covered in the US cosmetics export guide, and the EU (CPNP) in the article that follows.

This guide is general information as of July 2026. China's cosmetics rules and CBEC policy change frequently, so verify with NMPA notices and a specialist before you export.