French cosmetics sell well in China and the regulatory route is the part that surprises people. Not because it is opaque — it is unusually well documented — but because its structure is different from Europe's. Europe asks you to hold a safety file and notify. China asks you to obtain a decision, through a Chinese entity that becomes accountable for your product.
Special or general: the fork that sets your calendar
- Special cosmetics — hair dyes, permanent waving, freckle-removing and whitening products, sunscreens, anti-hair-loss products, and anything making a new claim. These require registration: prior approval, a certificate with a term, renewable.
- General cosmetics — everything else. These go through notification: a filing, an electronic certificate without a term, and a mandatory annual report.
The difference in elapsed time is substantial — notification is a matter of months, registration commonly runs to about a year — and the classification is not always obvious. A moisturiser with an SPF claim is a sunscreen. A serum claiming to even out skin tone may land in the special category depending on how the claim is worded. Deciding the wording of your claims is therefore a regulatory decision before it is a marketing one.
The domestic responsible person
Every imported cosmetic must have a domestic responsible person established in mainland China. They file the dossier, hold it, and carry responsibility for compliance, adverse-event reporting and recalls. A foreign manufacturer cannot file directly. There is no workaround.
This makes the choice of that entity one of the most consequential you will make. Brands routinely appoint their first distributor, which feels efficient and creates a problem: the registration sits with the distributor. Change distributor and you may be renegotiating for your own product's certificate. Keeping the responsible person separate from the commercial partner costs more and keeps the asset yours.
Ingredients and animal testing, stated precisely
Any ingredient absent from the Chinese inventory is a new cosmetic ingredient and carries its own procedure, with a monitoring period. A single unlisted ingredient can therefore govern the whole timeline — check your formula against the inventory before you plan anything else.
On animal testing, be careful with what you read. An exemption route exists for imported general cosmetics, but it is conditional: it requires, among other things, a good manufacturing practice certificate issued by the authority of the country of manufacture and a complete safety assessment. Products for children are excluded, several special categories remain subject to testing, and post-market testing stays legally possible. “China no longer requires animal testing” is not an accurate sentence, and a brand that builds its European communication on it is taking a real reputational risk.
Cross-border e-commerce is the way in without registration or notification, and it is a genuine route to test demand. Its limit is structural: it does not open physical retail. Treat it as a market test, not as a strategy, and start the regulatory file while it runs.
Where to read it yourself
Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.