China is one of the most attractive growth markets for cosmetic products worldwide. For many European brands, the Chinese market is therefore a logical next step on the path to international expansion. However, this is precisely where the first challenge often arises: A product that can be marketed fully legally within the European Union does not automatically meet the regulatory requirements in China.
Since the introduction of the Cosmetic Supervision and Administration Regulation (CSAR), China has fundamentally modernized its regulatory requirements for cosmetic products. The regulations have become more comprehensive, the documentation requirements more extensive, and the requirements for safety assessments significantly more precise.
Many manufacturers underestimate the effort required for a successful market launch in China. In practice, we regularly see companies only discover shortly before the planned export that important documents are missing or that existing documents do not meet the requirements of the Chinese authorities.
What is CSAR?
The Cosmetic Supervision and Administration Regulation (CSAR) forms the regulatory basis for cosmetic products in China. Similar to the European Cosmetics Regulation, it governs the conditions under which products may be manufactured, registered, imported, and marketed.
The aim of the regulation is to increase product safety while clearly defining the responsibilities of all stakeholders. The National Medical Products Administration (NMPA) is responsible for its implementation and monitoring.
For European manufacturers, this means one thing above all: Anyone wishing to tap into the Chinese market must address the local regulatory requirements early on.
Why EU conformity alone is not enough
One of the most common misconceptions is to assume that having a CPSR, a complete product information file, and a successful CPNP notification automatically grants access to the Chinese market.
In fact, numerous differences exist between European and Chinese regulations. Particularly regarding safety assessments, ingredient requirements, documentation obligations, and registration procedures, separate regulations apply.
In many cases, existing documents need to be expanded, adapted, or completely recreated. This applies particularly to the safety assessment, which in China is considered an independent component of the approval process.
CPSR and China Safety Assessment – similar goals, different requirements
Both the European CPSR and the Chinese Safety Assessment pursue the same goal: to prove that a cosmetic product is safe when used as intended.
However, the approaches differ considerably in some respects. While European safety assessments are based on the requirements of the EU Cosmetics Regulation, the NMPA requires additional evidence and specific assessment methods.
Therefore, while an existing CPSR can serve as a valuable basis, it does not automatically replace the requirements of the Chinese authorities.
It is precisely at this interface that delays in the approval process often occur.
What documents are required for China?
Depending on the product category and sales model, different documents may be required. These typically include:
- Safety assessment according to Chinese requirements
- Detailed product formulation
- Raw material information
- Test reports and laboratory analyses
- Identification documents
- Production certificates
- GMP documentation
- Registration documents for the NMPA
The completeness and quality of these documents often determine whether a process runs smoothly or is delayed for months.
Animal testing: What is really true today?
Hardly any topic causes more uncertainty than the question of animal testing.
In fact, China has significantly modernized its regulations in recent years. For many so-called “general cosmetics,” exceptions to animal testing can now be used, provided certain conditions are met.
This includes, among other things, complete safety documentation, GMP evidence and compliance with other regulatory requirements.
Nevertheless, each product should be individually assessed, as different requirements may apply depending on the product type and risk classification.
Typical defects of European manufacturers
In regulatory projects, we repeatedly encounter similar challenges:
- Underestimating Chinese documentation requirements
- Missing safety data for individual raw materials
- Incomplete product files
- Incorrect labeling
- Regulatory planning too late
- Lack of coordination with NMPA requirements
These errors often lead to unnecessary costs, delays, and additional checks.
Successfully entering the Chinese market – with the right regulatory strategy
The Chinese cosmetics market offers enormous potential for European brands. At the same time, it is one of the most regulatory demanding markets worldwide.
Early preparation, robust security documentation and sound knowledge of CSAR requirements are crucial success factors for a successful market entry.
The Cosmetic Safety Institute supports manufacturers, brand owners, and importers in the regulatory preparation of cosmetic products – from safety assessment and documentation review to strategic consulting for international markets. By combining regulatory expertise, practical project experience, and a deep understanding of European and international cosmetic regulations, we help companies identify regulatory risks early and efficiently prepare for market launches.
Are you planning to export your cosmetic products to China? We would be happy to assist you in evaluating your current documentation and preparing for the next regulatory steps.
