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Guide
What overseas documents are usually required
Imported cosmetics usually require three kinds of overseas paperwork in addition to the core dossier: proof that the product is already marketed in the country of the registrant, filer or manufacturer; the original sales packaging and a Chinese translation of the foreign-language label; and documents that show the manufacturing or authorization relationship. The law also describes cases in which marketing proof may be omitted, including formulas designed specifically for the China market and, where Announcement No. 70 of 2026 applies, certain first or simultaneous launches supported by a commitment statement.
How to judge which papers you need
The Provisions on Management of Cosmetics Registration and Filing Dossiers require imported products to provide marketing proof issued by a government authority or industry association in the country of the registrant or filer or the country of manufacture, together with the sales packaging used there and a Chinese translation. If the brand commissions an overseas factory, a manufacturing agreement is also required. A quality-management certificate issued by the manufacturer’s home authority is often needed if you intend to rely on a toxicology waiver.
When marketing proof may be omitted
The rules allow marketing proof to be omitted when a domestic registrant or filer commissions an overseas manufacturer, and when the formula was designed specifically for the China market. Designing only a China-specific outer carton, while the formula and process remain those of an overseas product, is not the same situation and should not be stretched into that exception. NMPA Announcement No. 70 of 2026 further provides that an international new product launched first in China, or launched in China at the same time as in other countries or regions, may submit a commitment statement of China-first listing instead of marketing proof, and may use design drawings of the country-of-manufacture sales packaging. Whether a product meets those conditions should be judged against the announcement and current system requirements, not expanded by analogy.
Cautions
Marketing proof should at least identify the registrant, filer or manufacturer, the product name, the issuing body and the date, and bear the issuer’s seal. For kits that combine imported and domestic items, proof is usually needed only for the imported portion. Language, notarization and authentication follow the requirements then in force.
Questions we are often asked
Does a free-sale certificate from any chamber of commerce always work?
The file should come from a competent government authority or an industry association as required by the dossier rules. Whether a particular issuer is acceptable is judged against those rules and current review practice.
Is a commitment statement available for every new SKU?
No. It is tied to the China-first or simultaneous-launch conditions in Announcement No. 70 of 2026. Do not treat it as a general substitute for marketing proof.
Next step
Discuss your China market path
Tell us whether you plan to import finished goods or manufacture in mainland China, and what the product claims. We will outline the likely filing or registration path. Testing, where needed, is arranged with partner laboratories.
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