Cosmetic products which are not classified as “special-use cosmetic” in China, like products for skin care, body care, hair care, lipsticks 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 Person (RP) as its representative for filing. A RP should be registered in mainland China with business scope of cosmetic import and sale in China. RP is not just a simple representative in China but takes a lot of responsibilities in China, such as all issues related with cosmetic filing and products’ quality and safety sold in China, assisting cosmetic adverse reaction monitoring and recalling, and cooperating with competent authorities’ on-site inspection.
One oversea cosmetic manufacturer can appoint different responsible persons for different products, but one product can only match with one unique responsible person at one time. RP can be changed but need the previous one’s informed consent.
The whole filing process may take 3-5 months.
