The first question I get from foreign beauty founders is almost always the same. Do I need to register my brand in China, or get a business license, before I can sell a single lipstick? The honest answer has two parts. You do not need a Chinese business license to reach Chinese buyers, because cross-border e-commerce lets you sell from abroad. But whether your product needs to be registered or notified with the regulator depends entirely on how it enters the country. People mix these two things up constantly, and it costs them money. Let me separate them clearly.
Written by Olivier Verot, founder of Gentleman Marketing Agency, based in Shanghai since 2012. I have helped dozens of cosmetics and skincare brands enter China through cross-border channels and, when they were ready, through general import with full NMPA filing. This article is about the difference, and why it matters.
License and product registration are not the same thing
A business license means a legal entity registered in mainland China. A product registration or notification means your specific formula has been declared to the National Medical Products Administration, the NMPA. These are two separate walls, and cross-border e-commerce only lets you skip one of them.
If you sell through a cross-border platform like Tmall Global or a bonded warehouse model, your goods are treated as personal imports bought by the Chinese consumer directly from abroad. No local company needed on your side, and no prior NMPA filing for most ordinary cosmetics. If instead you want your product on shelves in a physical store in Shanghai, or in the general import channel, that is a different regime. There, registration or notification is not optional.
What CSAR actually requires in 2026
China rewrote its cosmetics rulebook in 2021. The Cosmetic Supervision and Administration Regulation, known as CSAR, took effect on 1 January 2021 and still governs the market in 2026. Under CSAR, any cosmetic sold through the general import channel must be either registered or notified before it can legally reach the market. The regulation splits products into two groups, and the group decides the path.
- Special cosmetics need full registration, meaning pre-market approval by the NMPA. This covers products claiming whitening or freckle removal, sunscreen, hair dye, perm, anti-hair-loss, and any new efficacy claim. Expect a long process. In practice this runs well over a year per SKU, sometimes closer to two, with animal testing questions and a dossier to prepare.
- Ordinary cosmetics, meaning most skincare, makeup, and basic care products, only need notification, a record-filing with the NMPA. Faster than registration, but still a formal step with a responsible person inside China, testing reports, and ingredient compliance.
So in the general import regime, there is no such thing as selling cosmetics in China without registration or notification. That part is not negotiable. If a supplier tells you otherwise for a physical-retail launch, be careful. I would double-check any specific ingredient or claim with a licensed regulatory firm before committing, because the special versus ordinary line is not always obvious, and a single functional claim can move your product into the harder category.
How cross-border e-commerce changes the equation
This is where the “no registration” idea comes from, and it is partly true. Under the cross-border retail import model, cosmetics are regulated as goods for personal use. That exempts them from the prior NMPA registration or notification that the general import channel demands. It is the reason a small Korean or French brand can test China without a local entity and without a two-year filing.
But exempt from filing does not mean exempt from rules. Here is what still applies, and what trips brands up.
- The positive list. Only product categories on the official cross-border positive list can enter this way. The list has expanded over the years and now covers around 1,476 tariff lines, including most cosmetics and skincare. If your item is not on it, the channel is closed to you.
- Purchase caps. The personal-use logic comes with limits. The long-standing thresholds are 5,000 RMB per single transaction and 26,000 RMB per person per year. Beyond that, the general import rules kick in. The rules around these caps are being adjusted, and I cover the 2026 changes in our China CBEC law update.
- No physical retail. Cross-border goods cannot legally be sold in brick-and-mortar stores in mainland China. The moment you want a counter in a mall, you are back in the general import regime, and you need the filing.
- Border controls and product responsibility. Customs still inspects. Labeling and consumer-facing requirements still apply. And you remain responsible for product safety. A pilot for electronic labels started on 1 February 2026, and new customs and supervision measures for imported cosmetics are rolling out, so this space is tightening, not loosening.
My advice to founders is blunt. Treat cross-border as a legitimate low-risk way in, not as a loophole. I never recommend structuring an entry to dodge the regulator. Brands that try to look like personal imports while running real retail volumes get caught, and China has been sharpening enforcement on exactly this.
The market that makes this worth the trouble
The regulation is a hurdle, but the reason people jump it is simple. China is one of the largest beauty markets on earth, and it is still growing. Retail sales of cosmetics reached about 465.3 billion RMB in 2025, up 5.1% year on year, and the momentum carried into 2026, with sales rising 5.6% in the first four months against the same period a year earlier. Online is where most of it happens now, with e-commerce accounting for more than half of cosmetics sales.
That online tilt is good news for a foreign brand, because cross-border sits online by definition. Skincare remains the strongest category, and Chinese buyers are more ingredient-literate than most Western consumers I meet. They read INCI lists. They compare efficacy data. A vague “natural glow” claim does nothing here.
Getting seen: where demand is created in 2026
Being allowed to sell is one problem. Being found is a bigger one, and it is where most brands quietly fail. A cross-border store nobody visits is not a business. Here is how demand actually forms today, and the mechanism behind each channel.
- Xiaohongshu, the search-and-review engine. Chinese women research skincare on Xiaohongshu before they buy, the way others use Google. The mechanism is user-generated reviews and comparison notes. You seed authentic content, real skin-type results, real ingredient talk, and the platform’s search surfaces you when someone looks up your category. No notes, no discovery.
- Douyin interest commerce. Douyin does not wait for a search. Its algorithm pushes short video and livestreams to people who never asked for you, based on behavior. For beauty, a demo of texture and before-after is what converts. The mechanism is impulse, triggered by the feed, closed inside the same app.
- KOC and affiliation over big KOLs. A single celebrity key opinion leader gives you a spike, then silence. Dozens of smaller key opinion consumers, paid on affiliation, give you a steady stream of credible reviews at lower cost. The mechanism is trust at scale, because a stranger with 8,000 followers reads as a real user, not an ad.
- Generative search and private domain. More Chinese buyers now ask AI assistants like DeepSeek and Doubao for product recommendations, so the content you place on Chinese platforms increasingly feeds those answers. And a WeChat private-domain base, your own group of past buyers, gives you repeat sales without paying for traffic twice.
A Korean brand that learned the difference the hard way
Yuna ran a small Korean skincare brand, mostly serums and a whitening essence. She had read that China needed no registration, so she assumed she could ship freely. Her first shipment through a bonded cross-border warehouse held at customs, because the whitening essence made a functional claim that pushed it toward the special-cosmetics category, and the product had no NMPA approval to back that claim in a general-import context. She lost roughly two months and a chunk of stock sitting in bond.
What she tried first was to push harder on paid ads to a store that had almost no reviews. It burned budget and converted at close to nothing, because Chinese buyers would not trust an unknown serum with an empty review page. That failed for a clear reason: discovery in beauty is social, not paid-search.
What worked was splitting the range by regime. We kept the plain hydrating serums, ordinary cosmetics, on cross-border where no filing was needed, and used them to test demand. We reframed the whitening essence’s claims to stay compliant while its NMPA path was prepared for later. Then we built a Xiaohongshu review base with KOC seeding before scaling ads, so the store had social proof first. Over about nine months, her cross-border monthly revenue moved from near zero to a steady mid-five-figure dollar range, and only then did we start the formal notification for the products worth registering. The lesson she gives other founders now: cross-border is the door, not the whole house.
So, can you sell without registration or license?
Yes and no, and the distinction is the whole point. You can sell to Chinese consumers with no Chinese business license and, through cross-border e-commerce, with no prior NMPA filing for most ordinary cosmetics. You cannot sell in the general import channel, or in physical stores, without registration or notification, and special-claim products always need the harder registration path. Anyone who promises you a full China launch with zero regulatory work is either talking only about cross-border or cutting a corner you do not want to be standing near when customs tightens.
How our agency helps beauty brands enter China
Gentleman Marketing Agency has helped foreign cosmetics and skincare brands launch in China since 2012, starting on cross-border and moving to general import when the volumes justify the filing. We handle the store setup, the Xiaohongshu and Douyin content, the KOC and KOL work, and the WeChat private domain that keeps buyers coming back. We are marketers, not a law firm, so for the NMPA dossier itself we work alongside licensed regulatory partners. Contact us if you want a clear read on which regime fits your product.
FAQ
Do I need a Chinese company to sell cosmetics through cross-border e-commerce?
No. That is the main advantage of the cross-border channel. Your goods are sold to Chinese consumers as personal imports from abroad, so you do not need a registered legal entity in mainland China to start. You will need a store on a cross-border platform, a logistics or bonded-warehouse setup, and compliant labeling. A local entity only becomes necessary when you move into general import or physical retail.
Is NMPA registration ever required for cross-border sales?
For most ordinary cosmetics sold purely through the cross-border retail model, prior NMPA registration or notification is not required, because the goods are treated as personal use. The filing becomes mandatory the moment you switch to general import or want physical-store distribution. Special cosmetics, meaning whitening, sunscreen, hair dye and similar claims, always need full registration in the general channel. Verify your specific product’s category with a regulatory specialist before you commit.
What is the safest way to start if I am unsure about compliance?
Start on cross-border with your ordinary, no-claim products. It carries the lowest regulatory load and lets you test real demand before spending on filings. Keep any special-claim product out of the first wave until its NMPA path is prepared. Build social proof on Xiaohongshu before scaling ads. This staged approach limits your risk and gives you sales data to decide what is worth registering for the general market.
