Can I export a whitening serum, and is it treated like a whitening cream?

Q: Can I export a whitening serum, and is it treated like a whitening cream?

Yes, a whitening serum can be placed on the China mainland market, and it is treated like a whitening cream for classification purposes: both are special cosmetics used for whitening or spot-removal and must be registered. A fluid, ampoule or essence format does not move the product onto ordinary filing, and it cannot use the about 10–20 day ordinary-filing cycle. A serum that only moisturizes or that makes a non-whitening claim may be an ordinary cosmetic if that is its true intended use.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

Judge the claims and intended effect, not the word “serum.” Fading spots, reducing pigmentation or whitening the skin are special-cosmetic functions whether the base is a cream, lotion or water-light essence.

Vitamin C or antioxidant positioning is not automatically whitening, but Chinese text that clearly communicates whitening will be read that way. See vitamin C or antioxidant serums and whitening creams.

Typical documents, tests and labels

Prepare the same type of special-cosmetics dossier you would prepare for a whitening cream, including human efficacy evaluation. For whitening or spot-removal registration, human efficacy method I is about 6 months and method II about 8 months, and review is about 12 months after testing is finished. Actual time depends on completeness and supplementary requests. Do not use the about 10–20 day ordinary-filing cycle. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform. After a record is issued, check it on the official NMPA filing query https://hzpba.nmpa.gov.cn/gccx/ and the NMPA data-search page https://datasearch.nmpa.gov.cn/datasearch/home-index.html#category=hzp.

Cautions

For general-trade import of a finished product, complete the required filing or registration before import, appoint a Domestic Responsible Person, and apply a Chinese label that meets the Cosmetics Labeling Rules. Customs and inspection-quarantine formalities are a separate process. Cross-border e-commerce retail import is a different channel with list, platform and personal-use limits; it is not a blanket “no filing” rule and not a path to unrestricted domestic resale.

Do not file a whitening serum as ordinary skincare and then keep whitening language on the website or outer carton.

Questions we are often asked

Does a higher concentration make it a drug?

Concentration alone does not turn a cosmetic into a drug, but the ingredients must be allowed for cosmetics and the claims must stay inside the cosmetic definition. Disease-treatment claims are not cosmetic claims.

Can one whitening-cream study cover a later serum?

Only if the products actually qualify to share data under the rules in force, including any similar-formula conditions in Announcement No. 70 of 2026. Different bases are not automatically the same product.