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Facilitation for Cosmetics Imports in China


updated on 30 June 2021 / reading time approx. 1 minute
Effective May 1, 2021, the Administrative Provisions of Cosmetics Registration and Filing of the China National Medical Products Administration (NMPA) came into effect. The regulations significantly facilitate the export of cosmetics to China. In particular, the previously required mandatory animal testing prior to marketing is no longer necessary, provided that particular requirements are met.


Two categories for cosmetics

There are two categories for cosmetics in China: Cosmetics for general use and cosmetics for special applications. The elimination of animal testing applies to cosmetics for general use. These include, for example, makeup such as mascara, blush and lipstick, skin care products and hair care products such as shampoo, perfumes, fragrances, toothpaste as well as nail polish. Cosmetics for special applications - including, for example, hair dyes, products for removing freckles and brightening the skin, sunscreens, hair loss products and products claiming special efficacy - are still subject to the requirement of prior animal testing before they can be placed on the market.

Requirements to waive animal testing

The following requirements must be met to waive animal testing for cosmetics for general use:

  • Existence of a quality management system certificate (QMS certificate) for production, issued by a government body in the country of production (in the case of export of products of a manufacturer from several countries of production, corresponding official certificates in each case),
  • Proof of product safety,
  • Products are not intended for infants and children,
  • Products do not contain new ingredients that are not approved in China, and
  • The applicant/responsible person in China is not flagged as subject to special monitoring in NMPA's evaluation system.

In this respect, there is a problem for many manufacturers that no official QMS certificates are issued in their production countries, but instead such certificates are often issued by industry associations or standardization organizations. Consequently, the respective countries should establish procedures for obtaining official QMS certificates.


Overall, the new regulations can be welcomed. Not only do they level the playing field with cosmetics manufacturers who were already exempt from animal testing in the past, but they also allow companies to enter China's multi-billion dollar and rapidly growing cosmetics market, which was previously only accessible to manufacturers to a very limited extent, e.g. through cross-border e-commerce sales, for ethical reasons and the rejection of animal testing, not to mention the prevention of animal suffering, even though animal testing has not yet been completely abolished.

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