China Cosmetic Registration Under CSAR (NMPA): A 2026 Guide

To sell a cosmetic in mainland China you must clear the Cosmetics Supervision and Administration Regulation (CSAR), the framework enforced by the National Medical Products Administration (NMPA). The single decision that shapes your entire timeline is classification: "special cosmetics" require pre-market registration (approval) by the NMPA, while "general" (ordinary) cosmetics require only filing (notification).

China is one of the largest and fastest-growing beauty markets in the world, but it is also one of the highest-barrier. Every imported product needs a China-based Responsible Person, every ingredient must clear the IECIC inventory, and every claim must be substantiated. This guide walks through how registration and filing actually work under CSAR, and where brands most often get caught.

What is CSAR, and who is the NMPA?

CSAR is the Cosmetics Supervision and Administration Regulation (formally, the Regulations on the Supervision and Administration of Cosmetics), promulgated as State Council Decree No. 727 on 29 June 2020 and effective 1 January 2021. It was the first comprehensive overhaul of China's cosmetic rules in over three decades, replacing the 1989 Regulations Concerning the Hygiene Supervision of Cosmetics (the framework often shortened to CSHIPS) that had governed the sector since 1989.

The regulator is the NMPA (National Medical Products Administration), China's counterpart to bodies like the US FDA or the EU's competent authorities. CSAR is a high-level regulation supported by detailed implementing rules, most importantly the Provisions for the Registration and Filing of Cosmetics (SAMR Order No. 35), which took effect on 1 May 2021 and set out exactly how registration and filing dossiers are built and reviewed.

If you are mapping China against other markets you already sell in, it helps to read this alongside our guides to the EU Cosmetics Regulation (EC) No 1223/2009 and MoCRA in the United States — the vocabulary overlaps, but the obligations differ significantly.

General vs special cosmetics: the classification that drives everything

Under CSAR, every cosmetic falls into one of two buckets, and that choice determines your submission type, your review path, and your timeline. Special cosmetics must be registered — meaning the NMPA reviews the dossier and grants approval before the product can be sold. General cosmetics only need to be filed (notified), and can generally go to market once the filing is accepted on the platform.

CSAR defines special cosmetics as products for hair dyeing, hair perming, freckle removal and whitening, sun protection (sunscreen), and hair-loss prevention, plus any cosmetic that claims a new efficacy. Everything else — most skincare, shampoos, color cosmetics, cleansers and fragrances — is a general (ordinary) cosmetic.

Attribute	General (ordinary) cosmetics	Special cosmetics
Submission type	Filing / notification (record-filing)	Registration (formal approval)
Pre-market NMPA approval?	No — market once the filing is accepted	Yes — must be approved before sale
Where it is submitted	NMPA (national level) for imports; provincial medical products administration for domestically made products	NMPA (national level)
Typical examples	Moisturizers, serums, shampoo, makeup, fragrance, cleansers	Hair dye, perms, freckle-removing/whitening, sunscreen, anti-hair-loss, new-efficacy claims
Relative timeline	Faster — often weeks to a few months	Slower — commonly several months up to around a year, with extra efficacy testing
Approval document	Filing record (no fixed expiry)	Registration certificate, valid for 5 years and renewable

The distinction also tracks a risk logic that runs through CSAR: the NMPA applies registration to higher-risk products and ingredients, and filing to lower-risk ones. Get the classification wrong and you either over-invest in a registration you did not need, or — far worse — sell a special-cosmetic product on a filing that never authorized it.

You must appoint a China-based Responsible Person

CSAR makes a domestic Responsible Person (often abbreviated RP or DRP) mandatory. This is a legal entity established in China that submits the registration or filing, is named on the certificate, and is legally accountable for the product's quality, safety and efficacy claims in the Chinese market. A foreign brand cannot register or file directly; it must act through a China-based RP.

The RP's duties go well beyond paperwork. It handles the online submission, retains the safety and testing records, manages adverse-event and safety monitoring, cooperates with NMPA inspections, and is the entity that faces enforcement if something goes wrong. For imported products the RP is frequently the importer and must hold the appropriate business qualifications. The concept is broadly analogous to the EU's Responsible Person, but the accountability sits with an entity physically inside China.

Every ingredient must clear the IECIC

Before a formula can be registered or filed, each ingredient has to be permitted for cosmetic use in China. The reference list is the IECIC — the Inventory of Existing Cosmetic Ingredients in China. The current edition, IECIC 2021, was issued by the NMPA on 27 April 2021 and catalogues the ingredients with an established history of cosmetic use in China, along with usage conditions such as maximum levels for certain substances.

If an ingredient is not on the IECIC, it is treated as a New Cosmetic Ingredient (NCI) and must be authorized before use. China splits NCIs by risk:

• High-risk NCIs (for example, certain preservatives, UV filters, colorants and hair-dye substances) require registration — a formal NMPA approval.
• Medium- and low-risk NCIs require the lighter-touch notification (filing).

After an NCI is registered or notified, it enters a 3-year safety-monitoring period, during which the registrant or notifier must report usage and safety data to the NMPA. If no safety problems emerge over those three years, the ingredient is folded into the existing-ingredient inventory. This monitoring status matters for more than paperwork — as the next section explains, it directly affects whether a product can skip animal testing. For a broader view of what is outright prohibited or restricted across regions, see our list of banned cosmetic ingredients by market.

Is animal testing still required to sell cosmetics in China?

This is the question that has changed the most, and the honest answer is "it depends." Historically, China required pre-market animal testing on essentially all imported cosmetics, which kept many cruelty-free brands out of the market. Since 1 May 2021, imported "general cosmetics" can be exempted from mandatory pre-market animal testing — but only when specific conditions are met, and several product types are carved out entirely.

To qualify for the exemption, the domestic Responsible Person must provide two things: a Good Manufacturing Practice (GMP) certificate for the manufacturer issued by the competent authority of the product's home country, and a completed product safety assessment. Where those are in place, the imported general cosmetic can rely on non-animal methods instead of mandatory pre-market animal testing.

Scenario	Mandatory pre-market animal testing?
Imported general cosmetic, with a home-country GMP certificate and a completed safety assessment	Can be exempted
Any special cosmetic (sunscreen, whitening, hair dye, perm, anti-hair-loss, new efficacy)	Not exempt
Products intended for infants and children	Not exempt
Products using a new ingredient still within its 3-year safety-monitoring period	Not exempt
Products flagged for special scrutiny (for example, an RP or manufacturer under heightened monitoring)	Not exempt

In short: the exemption is real and meaningful, but it is narrow. If your product is a sunscreen or a whitening cream, targets babies or children, or contains a still-monitored new ingredient, plan on testing. Brands making cruelty-free claims should confirm eligibility product-by-product rather than assuming China is now uniformly animal-test-free.

Safety assessment, product testing, and claim substantiation

Regardless of the animal-testing route, three evidentiary pillars underpin every China submission:

• Product safety assessment. CSAR requires a safety assessment for every product. Since 1 May 2025 the NMPA requires the full-format safety assessment report at registration or filing; the earlier "simplified" report is no longer accepted, so any dossier still relying on it is out of compliance.
• Product testing. Physicochemical, microbiological, toxicological and, where relevant, human-use testing must generally be performed by laboratories recognized in China, following the Safety and Technical Standards for Cosmetics. The NMPA continues to update accepted methods, including new-approach (non-animal) methods.
• Efficacy claim substantiation. CSAR requires evidence behind claims, and the standard rises with risk. Human efficacy trials are expected for claims such as whitening, sun protection (SPF/PA), anti-hair-loss and anti-acne. Efficacy evaluation summaries are published for transparency, so claims must be backed by data you can produce.

Chinese-language labeling is mandatory

Imported cosmetics must carry compliant Chinese-language labeling. The Chinese label content — including the product name, ingredient list, net content, RP details, and any safety and efficacy claims — must be consistent with the original (country-of-origin) label. You cannot make a claim on the Chinese label that is not supported on the original, and prohibited or exaggerated claims (for example, medical or absolute claims) are not permitted. Labeling errors are among the most common causes of filing rejections and post-market enforcement.

Step by step: registering or filing a cosmetic for China

1. Appoint a China-based Responsible Person — a qualified legal entity that will submit and be accountable.
2. Classify the product as general or special; this decides filing vs registration and your timeline.
3. Screen the full formula against the IECIC. Handle any New Cosmetic Ingredient through NCI registration or notification before you proceed.
4. Complete the full product safety assessment report in the current mandatory format.
5. Arrange product testing at China-recognized laboratories; for an imported general cosmetic seeking the animal-testing exemption, secure the home-country GMP certificate.
6. Substantiate efficacy claims, including human trials for whitening, sunscreen, anti-hair-loss or anti-acne claims.
7. Prepare compliant Chinese-language labeling that matches the original label.
8. Submit through the NMPA online platform — a filing for general cosmetics, or a registration dossier and technical review for special cosmetics.
9. Maintain post-market compliance — adverse-event and safety monitoring, annual reporting for new ingredients, and renewals (special-cosmetic registrations run five years).

This is where a compliance platform earns its keep. Cosmetica checks a formula against every target market's rules — including China's IECIC and CSAR requirements — and attaches a primary-source citation to every finding, across 15+ markets. That lets a brand see, before it commits to testing or a Responsible Person, which ingredients are inventory-listed, which claims will demand human trials, and whether a product is even eligible for the animal-testing exemption — rather than discovering it mid-submission.

Frequently asked questions

Is animal testing still required to sell cosmetics in China?

Not always. Since 1 May 2021, imported general (ordinary) cosmetics can be exempted from mandatory pre-market animal testing if the domestic Responsible Person provides a home-country GMP certificate for the manufacturer and a completed product safety assessment. The exemption does not apply to special cosmetics, products for infants and children, products using a new ingredient still in its 3-year safety-monitoring period, or products flagged for special scrutiny.

What is the difference between registration and filing under CSAR?

Registration is a pre-market approval process the NMPA applies to special cosmetics (and high-risk new ingredients) — the product cannot be sold until it is approved. Filing is a notification for general cosmetics that generally lets the product go to market once the filing is accepted. Registration takes longer and produces a certificate valid for five years; filings do not carry a fixed expiry.

Do I need a Responsible Person in China?

Yes. CSAR requires a domestic Responsible Person — a legal entity established in China that submits the registration or filing and is legally accountable for the product's quality, safety and claims. A foreign brand cannot register or file directly and must operate through a China-based RP, often the importer for imported goods.

What is the IECIC, and what happens if my ingredient is not on it?

The IECIC is the Inventory of Existing Cosmetic Ingredients in China, the NMPA's reference list of permitted cosmetic ingredients (current edition IECIC 2021). If an ingredient is not listed, it is a New Cosmetic Ingredient and must be registered (high-risk) or notified (medium/low-risk) before use, after which it enters a 3-year safety-monitoring period.

How long does China cosmetic registration take?

It varies by classification. Filing a general cosmetic can be relatively quick, often a matter of weeks to a few months once the dossier is complete. Registering a special cosmetic typically takes several months and can approach a year, because products such as sunscreens, whitening and anti-hair-loss items require additional efficacy testing before approval.

Are children's cosmetics treated differently?

Yes. Products for infants and children face heightened scrutiny under CSAR and its children's cosmetics rules, and they are excluded from the imported-general-cosmetic animal-testing exemption. Brands should plan for stricter safety substantiation and testing for this category.

Sources

Primary and official sources include the NMPA's announcement on implementing the Cosmetics Supervision and Administration Regulation, SAMR Issued the Provisions for Registration and Notification of Cosmetics (NMPA, English); the Provisions for the Registration and Filing of Cosmetics (NMPA, English), which sets out registration for special cosmetics and high-risk new ingredients versus filing for general cosmetics; the NMPA notice on the newly revised cosmetics regulation (State Council Decree No. 727); and the NMPA announcement on administration of the Inventory of Existing Cosmetic Ingredients in China (IECIC). General regulatory context was cross-checked against the NMPA's English portal at english.nmpa.gov.cn. This article is general information, not legal or regulatory advice; verify current requirements for your product and market before relying on it.