Can lash or brow growth serums be exported to China as cosmetics?

A product that claims to grow eyelashes or eyebrows, or to promote hair growth, is not a cosmetic under China’s classification rules. Those rules state that products which promote hair growth are not cosmetics. A serum that only conditions lashes or brows, without a growth or anti-hair-loss claim, may be an ordinary eye-area cosmetic and would be filed rather than registered. Drug-like prostaglandin treatments are not placed on the cosmetic path.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

Read every claim: longer lashes, new lash growth, “stimulates follicles,” or before-and-after growth photography usually leave the cosmetic category.

Anti-hair-loss is a special cosmetic function for reducing hair loss, and it is not a lawful substitute for a hair-growth claim. Eye-area products also attract the extra safety expectations that apply to the eye region.

Typical documents, tests and labels

If the product can stay a conditioning cosmetic, Testing and ordinary cosmetics filing may proceed in parallel. The ordinary filing cycle is about 10–20 days in total, depending on completeness and supplementary requests. That timing applies only to ordinary cosmetics filing, never to special cosmetics registration and not as a guaranteed import timeline. Prepare an eye-area safety assessment and a cautious Chinese label.

If the intended use is hair growth or medical treatment, do not force a cosmetic filing or registration. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform.

Cautions

Ingredient status is critical. Substances used as medicines for lash growth should not be assumed to be available as cosmetic ingredients. Check the current inventory and prohibited lists rather than copying an overseas formula.

Questions we are often asked

Can I rename a growth serum as a “lash conditioner”?

Only if the product’s real intended use, formula story and remaining claims are genuinely limited to conditioning. Keeping growth claims on the website while filing a conditioner creates an inconsistency.

Are brow dyes treated as cosmetics?

Hair-dye technical standards generally do not allow dyeing eyebrows or eyelashes with hair-dye products. Do not assume a hair-dye registration covers brows or lashes.