How to Sell Cosmetics in China: Routes, Rules and First Moves

A foreign beauty brand can sell to shoppers in China without filing a single product with the regulator. The cross-border retail rules in force since 1 January 2019 allow it (commerce ministry notice 486 of 2018). Or it can file every product and reach every shelf. How to sell cosmetics in China comes down to which route you take first, and for which products.

Cosmetics retail sales by China’s larger retailers reached RMB 465.3 billion in 2025, up 5.1% on 2024 (National Bureau of Statistics, January 2026). That series leaves out retailers under RMB 5 million in yearly revenue, so the whole market is bigger.

Planning a cross-border or flagship store in China? Talk to our China e-commerce team.

How to sell cosmetics in China: the order of moves

Selling cosmetics in China takes seven moves, and their order matters more than their speed. Each move sets up the next: a general-trade store opened before its products are filed has nothing it can legally stock.

1. Classify every product as general or special. Under China’s Cosmetics Supervision and Administration Regulation (CSAR, in force since 1 January 2021), the class decides filing or registration.
2. Choose a route per product: cross-border e-commerce (CBEC) to test demand, general trade to reach every channel.
3. Protect the name by registering your trademark in China, Chinese name included, before listing.
4. Appoint the partner your route requires: a China-registered company for customs on CBEC (notice 486 of 2018), a domestic responsible person for general trade (CSAR Article 23).
5. Build the file: safety assessment, claim evidence, Chinese label text.
6. Seed demand before the store opens.
7. Open one store, sell through one festival, then file what sold for general trade.

The exception is a brand planning pharmacy or department-store counters from year one. It starts general trade at move 2, because CBEC goods can’t be resold to stock a shelf (notice 486 of 2018).

What no sequence fixes is in why China entry strategies fail, and the market itself in our Cosmetics in China guides.

Cross-border or general trade: the two main legal routes

Foreign cosmetics reach Chinese consumers by two main legal routes. CBEC needs no filing with the NMPA, China’s cosmetics regulator (notice 486 of 2018). General trade needs a filing or a registration for every product before import (CSAR Article 17).

CBEC treats each sale as an import for the buyer’s personal use. Under notice 486, goods on the CBEC retail import list, sold through platforms linked to customs, skip the first-import licence, registration and filing rules. Each shopper can buy up to RMB 5,000 per order and RMB 26,000 a year (finance ministry notice 49 of 2018). The caps apply per shopper, not per brand: they limit basket size, not total sales.

General trade is the ordinary import route. Beyond the filing or registration, it needs a domestic responsible person, a Chinese label and import inspection (CSAR Articles 23, 35 and 45). In return, every channel opens.

The two routes side by side, from notices 486 and 49 of 2018 and the CSAR:

Our view: start most new brands on CBEC with one to three products, unless offline retail is the plan from the first year.

In 1943, a Rodgers and Hammerstein musical tried out at the Shubert Theatre in New Haven as Away We Go! (Shubert Theatre history page). Renamed Oklahoma!, it opened on Broadway at the St. James Theatre and ran 2,212 performances (Playbill, March 2021). A CBEC run is your New Haven: it shows which products, claims and prices work before you pay for a file. Unlike a tryout crowd, though, CBEC buyers are the same consumers you’ll sell to later.

Compare the stores in China’s cross-border e-commerce platforms, and see exporting cosmetics to China for general trade. A product’s class also shapes its route, the next decision.

General or special cosmetic: filing, registration and the file

China sorts every cosmetic into two classes under the CSAR (化妆品监督管理条例), State Council Decree No. 727, in force since 1 January 2021. Special cosmetics (特殊化妆品) need NMPA registration (注册) before import, and general cosmetics (普通化妆品) need a filing (备案) before import (Articles 16 and 17).

Special cosmetics are products for hair dyeing, perming, freckle removal and whitening, sun protection and hair-loss prevention, plus any product that claims a new efficacy (Article 16). Everything else is a general cosmetic, which covers most cleansers, moisturisers and make-up.

In our view, a sunscreen or a whitening claim in your range changes your timeline more than any channel decision.

The two classes compared, from CSAR Articles 13, 16, 17 and 20:

Filing a general cosmetic

A general-cosmetic filing is complete as soon as the dossier is submitted on the NMPA’s online platform, and the regulator publishes it within 5 working days (CSAR Article 20).

NMPA Announcement No. 70 of 2026, signed on 28 July 2026 and in force on publication, adds a launch option. A product launched first in China, or at the same time as abroad, can be filed on a China-first-launch commitment instead of proof of home-market sales. Our summary of No. 70 and No. 72 has the rest.

Registering a special cosmetic

A special-cosmetic registration runs on a statutory clock set by CSAR Articles 13 and 20. The NMPA passes the file to technical review within 3 working days. The review takes up to 90 working days, and the decision follows within 20 working days of the review opinion. A request for more data restarts the 90-day review when your answer arrives (SAMR Order No. 35, Article 39).

That clock covers the authority’s stages, not the time spent testing the product and building the file. If your hero product is a sunscreen, we’d start its registration file while the rest of the range tests on CBEC. For that product, the file sets the launch date, not the store.

Claims, labels and import checks

Every efficacy claim needs a sufficient scientific basis, and a summary of the evidence goes on a website the NMPA designates (CSAR Article 22). The brand, as registrant or filer, answers for the product’s safety and for its claims (Article 6).

Imported products can carry a Chinese label printed on the pack, or an added Chinese sticker whose content matches the original (Article 35). Goods that fail import inspection are not let in (Article 45).

The full rulebook is in China’s cosmetics regulations in full.

The domestic responsible person, and who holds your files

A foreign brand can’t file or register a cosmetic in China by itself. CSAR Article 23 requires it to designate a Chinese enterprise legal person, the domestic responsible person, to handle filing or registration, help monitor adverse reactions and carry out recalls.

The NMPA’s 2021 dossier rules call this partner the 境内责任人 and require the foreign brand to supervise its work (Announcement No. 32 of 2021). Changing responsible person no longer needs the outgoing partner’s consent (NMPA Announcement No. 70 of 2026, item 8). A notarised authorisation, the product list and the new partner’s commitment to take over its duties suffice.

Our recommendation is to keep the responsible-person role and distribution rights in separate contracts. When your distributor is also your responsible person, every change of distributor becomes a change on every file. Own your registrations, your stores and your official accounts, and give distributors regional offline rights rather than all of China.

Settle these points in writing with your responsible person:

• who holds the filing-account login;
• who receives the NMPA’s letters, and how fast;
• how adverse-reaction reports reach you;
• what happens to your files if the contract ends;
• who pays for file changes.

For the commercial side, see what Chinese distributors expect from a brand.

Animal testing in 2026: who is exempt

Since 1 May 2021, an imported general cosmetic can be filed without a toxicology test report, on two conditions (NMPA Announcement No. 32 of 2021, Article 33). Every factory that makes it must hold a manufacturing-quality certificate from its home government, and the safety assessment must confirm the product is safe. The NMPA counts that report as animal-test data (Announcement No. 70 of 2026, item 2).

The 2021 exemption excludes three cases: products claiming use by babies or children, products using a new ingredient still under safety monitoring, and companies placed under key supervision.

Sunscreens, oxidative hair dyes, anti-hair-loss products and whitening products that act on the skin rather than cover it are in neither exemption (Announcements No. 32 of 2021 and No. 70 of 2026). Their dossiers still include a toxicology report. CBEC products skip filing altogether, so they carry no toxicology file (notice 486 of 2018).

For a cruelty-free brand, the question is now per product, not per country. We’d check each product against both lists before choosing its route: a non-exempt sunscreen can stay on CBEC while exempt moisturisers move to general trade. Our earlier guide to China’s animal-testing rules for imported cosmetics has the 2021 detail.

Where to sell first

Your route decides your storefront. CBEC products sell through cross-border stores such as Tmall Global (天猫国际), while general-trade products can go anywhere, from Tmall (天猫) and JD (京东) flagship stores to retail chains. Douyin (抖音), Xiaohongshu (小红书) and WeChat (微信) shape the demand those stores convert.

Each channel maps to a route under notice 486 of 2018 and CSAR Article 17:

Douyin and Xiaohongshu also sell inside their apps; see opening a Douyin store and Xiaohongshu stores for beauty brands. Check which route each app’s store accepts for your category. WeChat fits repeat purchase; see selling through WeChat.

We’d open one store first. Two half-run stores split a launch budget that one store needs, and they split the early reviews too.

Build demand before the store opens

We recommend seeding content on Xiaohongshu before the first store opens, so a shopper who searches your brand finds posts and reviews, not silence. Our Xiaohongshu seeding team does exactly that.

A KOL (key opinion leader) is a creator with a large following, and a KOC (key opinion consumer) is an ordinary user whose reviews other shoppers trust. Our guides to KOL marketing for beauty brands and what a KOC is cover selection and briefs.

Lead with one hero product, not the full range: one product gives the seeding, the reviews and the store page a single story.

Our working model splits the jobs: Xiaohongshu for discovery, Douyin for conversion, a Tmall or JD store for the transaction, WeChat for repeat purchase. It breaks for low-price impulse products, which can go from first video to sale inside Douyin. On trust, see how foreign brands earn Chinese shoppers’ trust.

Two festivals set the calendar. 618 is JD’s anniversary sale in June, which JD calls China’s largest mid-year shopping festival (JD, June 2025). Double 11 (11.11) is Taobao and Tmall’s November festival (Alibaba Group, November 2025). Open the store and collect reviews before your first festival, not during it; see Double 11 for beauty brands.

Before the store opens, check that:

• the hero product is chosen and classified;
• the trademark is filed, Chinese name included;
• the Chinese product page and label text pass the claims rules above;
• seeding posts are live on Xiaohongshu;
• Chinese-language customer service is ready.

Planning your China launch

Two decisions from this guide set your first year in China: the route for each product, and the order you take the moves in. Classify, appoint, seed, then open.

You can read our published case studies first. For the store itself, our Tmall store management service opens and runs Tmall and Tmall Global flagship stores for beauty brands. Get in touch with your product list and target channels, and we’ll start from each product’s route.