Definition of Cosmetics

Under China's Cosmetic Supervision and Administration Regulations (CSAR), cosmetics are defined as daily-use chemical products applied to the human body surface, such as skin, hair, nails, or lips, by smearing, spraying, or other similar methods, for the purpose of cleansing, protecting, beautifying, or altering appearance.

Classification of Cosmetics

China classifies cosmetics into two main categories:

• Special Cosmetics: products with specific functions, including hair dyeing, perming, anti-freckle/ whitening, sunscreen, anti-hair loss products, and cosmetics claiming new efficacies.
• Ordinary Cosmetics: all other cosmetics, including general skin and hair care, body care, nail care, makeup, deodorants, perfumes, and toothpaste (which is now regulated as an ordinary cosmetic).

Note: Products intended for hair growth, breast enlargement, or body sculpting are not classified as cosmetics under CSAR.

Market Access Requirements

Except for cosmetics sold via cross-border e-commerce (which are currently exempt from registration), all cosmetics (excluding ordinary beauty soaps) must undergo filing or registration before being placed on the Chinese market.

• Special cosmetics require registration with the National Medical Products Administration (NMPA).
• Ordinary cosmetics require filing with the provincial-level MPAs.

Qualifications of Registrants and Filers

Registrants or filers are responsible for the quality, safety, and efficacy claims of their cosmetics. They must:

• Be a legally established enterprise or other organization;
• Maintain a quality management system suited to their cosmetics; and
• Have the capacity for adverse reaction monitoring and evaluation.

Role of the Domestic Responsible Person (DRP)

Foreign companies must appoint a domestic responsible person (DRP) to manage registration or filing. The DPR must:

• Submit applications on behalf