In China, general cosmetics are filed, not approved
China export checklists routinely put "obtain NMPA approval" against ordinary skincare. Ordinary skincare is filed rather than approved, and a filing number issues instead of a decision arriving. Announcement No. 70, published on 29 July 2026, dropped two ingredient documents from the list.
General cosmetics in China are filed (备案), not registered (注册). The Domestic Responsible Person uploads the dossier, a filing number issues, and sales can begin that day. Only hair dye, perms, whitening, sun protection, anti-hair-loss and new-efficacy claims go through NMPA review. Announcement No. 70 of 29 July 2026 removed the ingredient safety information document and the ingredient submission code from the dossier.
A filing is not a queue
The line that most often goes wrong on a China export checklist is "obtain NMPA approval." Ordinary skincare and colour cosmetics are not approval products. China splits cosmetics into special and general, and only the first group goes to the NMPA for a decision.
Five categories are special: hair dye, perms, whitening and spot correcting, sun protection, and anti-hair-loss. Any product claiming a new efficacy joins them. Everything else is filed — 备案, a notification.
The distinction decides a launch calendar. An approval product waits for a decision before it can sell; a filed product sells from the day its filing number issues. So "China approval takes six months" describes the special categories, and planning an essence or a cream around that figure leaves the first shipment sitting in a warehouse for two months.
| Special cosmetics | General cosmetics | |
|---|---|---|
| Route | Registration (注册) | Filing (备案) |
| Scope | Hair dye, perm, whitening, sun care, anti-hair-loss, new efficacy | Skincare, colour, everything else |
| Sales begin | On approval certificate | On filing number |
| Efficacy test data | Always submitted | Depends on the claim made |
| Applicant | Domestic Responsible Person | Domestic Responsible Person |
Two ingredient documents left the list on 29 July
The NMPA published Announcement No. 70 on 29 July this year. It took effect on publication, and it prevails where it conflicts with earlier NMPA documents.
The ingredient provisions are what brands will feel. The ingredient safety information document and the ingredient submission code are no longer entered. This is precisely where Korean brands used to stall — a supplier would not release its submission code, or the code existed but had lapsed and the entry was rejected. Filers now name the ingredient manufacturer and retain the supporting records themselves.
The rest of the announcement moves cost as well. A product launching first in China, or simultaneously in China and elsewhere, submits a China-first launch commitment statement instead of proof it already sells in the manufacturer's home market, and sales packaging for the country of manufacture can go in as a design drawing. A general cosmetic using a new ingredient is exempt from the toxicology report where the manufacturer holds a production quality management certificate from its home authority and the safety assessment carries the product. Children's cosmetics are excluded.
| Under Announcement No. 70 | Before | After |
|---|---|---|
| Ingredient safety info and code | Submitted and entered | Dropped; manufacturer named |
| Overseas marketing proof | Submitted | China-first commitment statement |
| Toxicology report | Submitted | Conditionally exempt (not children's) |
| Similar-formula test data | Per product | Shared from one representative |
| DRP change | Outgoing DRP's consent | Incoming DRP's notarised authorisation |
Shared data is worth most to brands with wide ranges. Where the registrant and the brand are the same, one representative product carries the microbiological, physicochemical, toxicological and human safety testing, and the rest go in with a formula-similarity explanation and a justification. Different production sites still need their own microbiological and physicochemical tests. Differences in colorants, fragrances, pH adjusters, polymeric thickeners and pearlescent agents stay inside the permitted range.
The Domestic Responsible Person is not an agency slot
A filing names one Domestic Responsible Person: a China-based entity carrying the filing, product release, adverse reaction monitoring and recall duties. One product, one DRP.
The difficulty here is contractual rather than regulatory. Name a local distributor as DRP and the filing number is tied to that company. Moving it used to need the outgoing DRP's sealed consent, which in practice meant a reluctant partner could block the move. Announcement No. 70 removed that consent document, replacing it with the incoming DRP's authorisation letter and notarised original, a list of affected products, and a commitment covering responsibility for products already marketed.
That lowers the barrier without making the move free. When the distribution agreement is drafted, who holds the DRP role deserves the same attention as the price terms.
The full safety assessment has applied since May 2025
Weight has shifted from the dossier to the safety assessment. The simplified version ended on 1 May 2025, and only the full version is accepted now.
The full version asks for each ingredient's safety margin to be supported by evidence. Seven types qualify: the Safety and Technical Standards for Cosmetics (2015), conclusions from internationally recognised assessment bodies, limits published by authorities such as the WHO and FAO, the regulator's published use information for marketed products, three years of ingredient use history, a safe history of food use, and structurally stable polymers. Where none fits, the route is TTC, read-across, or the four-step risk assessment procedure.
The regulator's published use data grew sharply on 9 February last year: ingredients went from 2,234 to 3,608, and use records from 4,415 to 7,672. An ingredient on that list arrives with one evidence type already in hand. Writing "formulate from listed ingredients where possible" into the brief cuts assessment cost noticeably. Which ingredients are moving now sits in today's ingredient signals, and a formulation direction can be taken through to a quotation in the product planner.
What finished-product testing can cover is narrow. It applies to low-level non-functional ingredients making up 10% or less of the formula, so a plan to cover an active that way comes back rejected.
Cross-border e-commerce sidesteps the filing
Selling through bonded or direct-shipping channels such as Tmall Global and JD Worldwide skips filing, animal testing and facility registration. That is why brands use the route to test demand first.
Only the exempted items are exempt, though. A Chinese e-label, a China-based importer or agent, customs declaration and the ingredient positive list all remain. Offline retail or general trade brings the filing back, so the moment cross-border numbers justify widening the channel is the moment to rebuild the regulatory calendar.
The background figures are worth reading alongside this. Korean cosmetics exports to China came to roughly USD 2.0 billion in 2025, down 19% year on year, handing first place to the US at about USD 2.2 billion. A falling China share arriving at the same time as a lighter dossier is an odd combination — and a reason for brands that stepped back from China to run the numbers again.
In short
- General cosmetics are filed, not approved; sales begin the day the filing number issues.
- Announcement No. 70 of 29 July 2026 dropped the ingredient safety information document and the submission code.
- Products sharing a brand and a similar formula can rely on one representative product's test reports.
- The outgoing DRP's consent is no longer needed for a change, but the role still belongs in the contract.
- Only the full safety assessment has been accepted since 1 May 2025, and the 3,608 listed ingredients make evidence easier to assemble.
*Sources: Announcement No. 70 — CNC News, REACH24H / full safety assessment and published ingredient data — ZMUni Compliance Centre / filing versus registration and CBEC — Portlogics / 2025 export figures — Cosmorning (MFDS data). Verified 11 October 2026.*
Questions people ask
Not for a general cosmetic. The Domestic Responsible Person files the dossier and a filing number issues, which is when sales start. Review and approval apply to the special categories: hair dye, perms, whitening and spot correcting, sun protection, anti-hair-loss, and products claiming a new efficacy.
The ingredient safety information document and the ingredient submission code are gone. Filers name the ingredient manufacturer and keep the supporting records on file. Products launching first in China may submit a commitment statement instead of overseas marketing proof, and products sharing a brand and a similar formula may rely on one representative product's test reports.
No. The DRP is a China-based legal entity that owns the filing, product release, adverse reaction reporting and recalls. One product carries one DRP. Changing it now takes the incoming DRP's notarised authorisation letter, a product list, and a commitment to assume responsibility for products already on the market.
Only the full version has been accepted since 1 May 2025. Each ingredient's safety margin needs support from one of seven evidence types, with TTC or read-across available where none fits. Finished-product testing can substitute only for low-level non-functional ingredients making up 10% or less of the formula.
Bonded and direct-shipping channels such as Tmall Global skip filing, animal testing and facility registration. A Chinese e-label, a China-based importer or agent, customs declaration and the ingredient positive list all still apply. Moving into offline retail or general trade brings the filing requirement straight back.