Cosmetic products which are not classified as “special-use cosmetic” in China, like products for skin care, body care, hair care and perfumes, are regarded as “non-special-use cosmetic”. Before the year 2017, the company which imports “non-special-use cosmetic” into China should finish the registration procedure before the importation starts. The regulation requirement has been amended to a filing procedure since Jan 2017. The new policy was piloted in China free trade zones first and then implemented nationwide from Nov 2018.
Different from the Responsible Agent (RA) requirement for “special-use cosmetics” importing company, the overseas company should appoint a Chinese legal entity called Responsible Legal Person (RP) as its representative for filing. A RP should be registered for cosmetic import and export business scope in China, and also take the responsibilities of the filing cosmetic product safety.
The whole filing process may take 3-5 months.
