If you sell cosmetics and you want China, the first wall you hit is not marketing. It is registration. Since January 1, 2021, every cream, serum, lipstick and sunscreen sold on the mainland falls under the Cosmetic Supervision and Administration Regulation, known as CSAR. This text replaced the old 1989 hygiene rules and it changed how foreign brands enter the market. Get the paperwork wrong and your product never reaches a Tmall shelf. Get it right and you have a legal, defensible position that competitors who cut corners do not have.
This guide explains what CSAR actually asks of a foreign brand in 2026: the split between special and ordinary cosmetics, the safety dossier that became fully mandatory in 2025, the efficacy proof behind every claim, new ingredient rules, the domestic responsible person, and the cross-border route that lets some brands test China with lighter filing.
Written by Olivier Verot, founder of GMA. I have helped European and American beauty brands enter China since 2012 from our Shanghai office, from the first NMPA filing to the launch on Tmall and Douyin. I have seen brands lose a year because they filed a whitening serum as an ordinary product. This is the article I wish they had read first. LinkedIn.
What CSAR is, and why it matters for foreign brands
CSAR is the top level regulation for cosmetics in China. Below it sit dozens of supporting texts published by the National Medical Products Administration, the NMPA, which is the central authority for registration, filing and safety oversight of cosmetics and their ingredients. The NMPA is the successor of the old CFDA, so if you read documents that still mention the China Food and Drug Administration, they refer to the same lineage of authority.
The logic of CSAR is simple to state and hard to execute. Every product is sorted into one of two boxes. The box decides whether you register or notify, how long it takes, how much it costs, and how much data you must produce. Choosing the wrong box is the most common and most expensive mistake foreign brands make.
Special cosmetics vs ordinary cosmetics: two very different roads
Special cosmetics must be registered with the NMPA before they can be sold. This is the heavy track, with pre-market technical review and a certificate valid for five years. Ordinary cosmetics only need a notification, a filing that lets you go to market once the record is accepted, with no fixed expiry on the record itself.
Under CSAR the list of special cosmetics was reduced to five clear categories plus a catch-all. A product is special if it does any of the following: hair dye, hair perming, freckle removing and whitening, sun protection, anti hair loss. The catch-all covers any cosmetic that claims a new function not yet recognised by the standards. Everything else, most skincare, most makeup, shampoos, fragrances, is ordinary and follows notification.
One point trips up nearly every newcomer. A brightening or whitening serum is not ordinary. A day cream with an SPF value is not ordinary. Both are special cosmetics and both need full registration. Children’s cosmetics carry their own reinforced rules and are treated with extra caution. Read the claim on your packaging before you assume the easy road.
| Criteria | Special cosmetics | Ordinary cosmetics |
|---|---|---|
| Procedure | Registration (pre-market approval) | Notification (filing) |
| Typical categories | Hair dye, perming, freckle/whitening, sunscreen, anti hair loss, new-function claims | Most skincare, makeup, shampoo, fragrance |
| Authority review | Technical review before launch | Records checked, market access faster |
| Certificate validity | 5 years, renewable | No fixed expiry on the record |
| Typical timeline | Several months to over a year | Weeks to a few months |
| Data burden | Highest | Lighter, but safety and efficacy still required |
The safety assessment dossier: full report now mandatory
Every product, special or ordinary, needs a cosmetic product safety assessment. This dossier shows that the formula is safe for its intended use. For years the NMPA allowed a simplified version of this report during a transition period. That grace period is over.
Since May 1, 2025, the full safety assessment report is compulsory for all registration and notification submissions. Any brand still relying on a simplified report is non-compliant. In practice the full report demands more raw data on each ingredient, toxicological endpoints, exposure calculations and impurity analysis. It is longer, more technical, and it must be signed by a qualified safety assessor. Budget for it early, because a weak safety file is the most frequent reason a foreign filing stalls.
Product testing tied to the dossier must be run by laboratories registered in the NMPA’s own management system. Overseas test reports are not automatically accepted, so plan on Chinese lab testing for most items.
The efficacy dossier: every claim needs proof
This is the part European brands underestimate the most. Since January 1, 2022, any efficacy claim on a cosmetic sold in China must be backed by evidence. You cannot write “anti-aging”, “moisturising for 24 hours”, “brightening” or “soothing” on the label unless you hold data that supports it.
Different claims call for different proof. Some can be supported by literature or by the raw material’s documented action. Others require human trials, laboratory tests or consumer-use studies, depending on the claim. The registrant must also publish a summary of the efficacy evidence on the NMPA website, where it is visible to the public and to competitors. Claims and their backing are on record. That is a discipline most brands are not used to, and it is exactly where a serious agency saves you time.
New ingredients and the domestic responsible person
If your formula contains an ingredient not already on China’s approved lists, it counts as a new cosmetic ingredient. High-risk new ingredients must be registered with the NMPA. Lower-risk ones can be filed. Either way there is a monitoring period: for three years after registration or filing, the applicant submits annual safety reports on the ingredient. Only after that clean record does the ingredient move toward the general approved lists. CSAR opened this door on purpose, to bring more innovation into China, but the door has a long corridor behind it.
Second, a foreign brand cannot file on its own. You must appoint a domestic responsible person, a legal entity based in China that holds the registration or notification and answers to the NMPA for the product’s quality and safety. For imported products this is usually the importer. Choose this partner with care. The responsible person controls your certificates. If the relationship breaks, your market access can break with it. I have seen brands trapped because their filing sat under an agent they no longer trusted.
Cross-border e-commerce: the lighter route to test China
There is a second door, and it is the reason many brands reach Chinese consumers within weeks rather than a year. Products sold through cross-border e-commerce, on bonded platforms like Tmall Global, are treated as personal imports. In that channel a brand can reach mainland shoppers without the full pre-market NMPA registration or notification that general trade demands. You still respect labelling and safety expectations, and you cannot stock the goods in physical mainland stores, but the regulatory entry is far lighter.
This is how I advise most brands to start: test demand cross-border, learn the Chinese consumer, build reviews, then invest in full registration for the products that prove themselves. One warning. The cross-border rules are not frozen. China has been tightening oversight of some categories and adjusting thresholds, so treat this route as a smart entry, not a permanent exemption. We track those shifts in detail in our guide to the China CBEC law and what changes for foreign brands.
What changed in 2024 to 2026
CSAR is not a one-off. The NMPA keeps sharpening it, and 2025 and 2026 brought concrete moves foreign brands must factor in.
- May 1, 2025: the full safety assessment report became mandatory for all submissions. The simplified version is gone.
- March 1, 2026: the NMPA folded twelve new or revised testing methods into the Safety and Technical Standards for Cosmetics. Five touch safety assessment directly, including BCOP for eye irritation, the kDPRA skin sensitisation test, in vitro skin absorption, immunotoxicity assessment and an oral mucous irritation test. Products filed after that date must carry compliant data for the newly required methods.
- Microbial limits: the NMPA introduced differentiated microbial limits for eye cosmetics, lip cosmetics and children’s cosmetics, part of a wider batch of standard revisions running through 2026.
- Toward alternative methods: several of the new tests are non-animal, in vitro methods, which brings China closer to the safety-testing approaches used in Europe. That is good news for brands that already hold European data.
The direction is clear. More proof, more precision, less room for a thin dossier. Brands that treat registration as a serious technical project win. Brands that treat it as a formality get stuck at customs. For the official reasoning behind these reforms, see the analysis by China Briefing, and for the safety report deadline the regulatory note from Cisema.
Case study: a Czech brand that filed the wrong box
Hana runs a natural skincare brand from the Czech Republic. Clean formulas, strong story, good sales in central Europe. She came to us after eight months of trying to enter China on her own, and she was stuck.
Her mistake was the classic one. She had assumed all six of her products were ordinary cosmetics and could go through simple notification. Two of them were not. Her hero product was a brightening serum, which China treats as whitening, so a special cosmetic requiring full registration. Her bestselling day cream carried an SPF claim, again special. On top of that, a cheap local agent had prepared a simplified safety assessment in 2024, and by the time the files moved in mid-2025 the full report was mandatory. Everything bounced. She had spent close to 12,000 euros and had zero products live.
We reset the plan. First we split the portfolio by regulatory box. The four true ordinary products went through notification with a proper full safety dossier and an efficacy file for each claim. The brightening serum and the SPF cream went into the registration track, with Chinese lab testing and a qualified safety assessor. In parallel we put the whole range on Tmall Global cross-border, so Hana could start selling and building reviews while the special products cleared registration. We also moved her filing under a domestic responsible person she actually controlled, not the old agent.
The four ordinary products were notified and live within about four months. The brightening serum completed registration in roughly eleven months, the SPF cream a little after. Cross-border sales in the meantime gave her the first 2,000 verified reviews and enough Douyin traction to justify the registration cost. Nothing here was magic. It worked because the products were finally in the right box, with the right dossier, held by the right entity.
FAQ: China cosmetics registration for foreign brands
Do I need NMPA registration to sell my skincare in China?
It depends on the box and the channel. For general trade, ordinary cosmetics need a notification and special cosmetics need full registration. If you sell only through cross-border e-commerce on bonded platforms like Tmall Global, you can reach consumers without full pre-market registration or notification, though you still meet safety and labelling expectations. Most brands test cross-border first, then register the winners.
What makes a product a special cosmetic?
Five functions trigger special status: hair dye, hair perming, freckle removing and whitening, sun protection, and anti hair loss. A sixth catch-all covers any product claiming a new function not recognised by the standards. So a brightening serum or an SPF moisturiser is special and needs registration. Read your own claims carefully, because the wording on the label decides the category.
How long does registration take?
Ordinary cosmetics can be notified in a few weeks to a few months once the dossier is ready. Special cosmetics take longer, often several months to more than a year, because of technical review and Chinese lab testing. The real timeline depends on how clean your safety and efficacy files are on day one. A weak dossier is what turns a six-month process into an eighteen-month one.
Can I use my European safety and efficacy data?
Partly. European data helps build the file and supports some claims, but China requires its own registered-lab testing for most products, and the full safety assessment must meet Chinese standards. The good news is that the 2026 adoption of non-animal, in vitro methods moves China closer to European practice, so more of your existing work can carry over than a few years ago.
Compliance is the entry ticket, not the finish line. In China no reputation means no trust, and no trust means no business. Once your product is legal, the next job is demand: Xiaohongshu reviews, Douyin content, KOC seeding and a real presence where Chinese shoppers decide. Start with our guide on why skincare is the bestseller category of China e-commerce and how Xiaohongshu works as a search engine for brands. You can also read our full guide on the top marketing strategies to succeed in the beauty market.
Work with GMA on your China cosmetics entry
GMA is a Shanghai-based agency that helps foreign beauty and skincare brands enter China the right way. We guide you through NMPA registration and notification, safety and efficacy dossiers, the domestic responsible person and the cross-border route, then build the demand on Tmall, Xiaohongshu and Douyin. Contact us to map your product portfolio against CSAR before you spend a euro on the wrong filing.
