Domestic Responsible Person

Who this is for

This service supports overseas brands that will file or register imported cosmetics and therefore must appoint a Domestic Responsible Person (境内责任人). The brand does not always need to incorporate its own Chinese subsidiary, but general-trade import is not possible without a Chinese enterprise legal person in this role.

What the law requires

The Cosmetics Supervision and Administration Regulation and the Measures for the Administration of Cosmetics Registration and Filing require an overseas registrant or filer to appoint an enterprise legal person in China. That person handles registration or filing in the name of the registrant or filer, assists with adverse-reaction monitoring and recalls, cooperates with supervision, and assumes corresponding quality and safety responsibilities under the agreement with the overseas company.

The role is not a mailbox. Quality and safety responsibility remains with the registrant or filer; the Domestic Responsible Person is the statutory arrangement through which those duties are performed in China.

What Jinshang organizes

We help overseas brands understand what the Domestic Responsible Person must do, what authorization documents are usually needed, and how the role fits into import filing or registration. We can work with an existing responsible person to compile the dossier. We do not take over that person’s legal duties.

NMPA Announcement No. 70 of 2026 simplified the documents used to change a Domestic Responsible Person. Current filings no longer require a stamped consent letter from the previous responsible person or a court judgment proving the change; the materials now centre on a notarized authorization, a product list and a commitment by the new responsible person. The exact package should follow the announcement and the system requirements in force at the time.