How to manufacture compliant cosmetics in mainland China

To manufacture compliant cosmetics in mainland China, use a factory that holds the appropriate cosmetics production licence, decide whether the product is an ordinary cosmetic or a special cosmetic, and complete filing or registration before the China-made product is placed on the market or, for special cosmetics, before production. Manufacturing locally does not allow a sunscreen or whitening product to use ordinary filing.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

If the last process in contact with the bulk is completed in mainland China, the product is a China-made cosmetic even when the brand owner is overseas. Ordinary China-made cosmetics are filed with the provincial authority where the filer is located. Special cosmetics are registered with the NMPA. The brand that acts as filer or registrant still needs a quality-management system and adverse-reaction monitoring capacity; it cannot outsource legal responsibility to the factory.

What to prepare

Prepare the core dossier and confirm the contract-manufacturing relationship through the information service platform. The factory’s name, address and licence number must match the actual production site. Labels of domestic products must include the manufacturer’s production-licence number. Tests are arranged with qualified laboratories; Jinshang coordinates them with partner labs.

Cautions

Do not start large-scale manufacture of a special cosmetic before registration is granted. If production later moves overseas, or a domestic site is added to an imported product, follow the change or re-filing rules then in force, including the documentation relief described in Announcement No. 70 of 2026 where its conditions are met.

Questions we are often asked

Can a foreign brand be the filer of a China-made product?

A filer must be an enterprise or other organization that meets the statutory conditions. In practice the China-side applicant is often a Chinese company in the group or a company that takes on the filer role. The arrangement should match the names that will appear on the label and in the system.

Does local manufacture avoid a Domestic Responsible Person?

The Domestic Responsible Person requirement applies to overseas registrants or filers. A China-made product filed by a domestic company does not use that import-specific role, but the domestic filer or registrant still carries the legal duties of that role.