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Guide
Can AHA, BHA or exfoliating products be exported to China?
Yes. AHA, BHA or other exfoliating products can usually be exported to China as ordinary cosmetics. Exfoliation is a listed ordinary efficacy: helping remove keratin or promoting keratin renewal. The acids must be substances allowed for cosmetics and used within any concentration, pH, product-type and labelling conditions in the Safety and Technical Standards for Cosmetics. Products presented as medical peels, or as treatments for a skin disease, are not cosmetics.
How to judge the path
Name each acid correctly in the formula—glycolic, lactic, salicylic or another listed substance—and match any restricted-ingredient footnotes, including rinse-off versus leave-on limits where they exist.
If the exfoliant also claims anti-acne, keep that claim inside the ordinary anti-acne definition and away from antibacterial or anti-inflammatory drug language.
Typical documents, tests and labels
Testing and ordinary cosmetics filing may proceed in parallel. The ordinary filing cycle is about 10–20 days in total, depending on completeness and supplementary requests. That timing applies only to ordinary cosmetics filing, never to special cosmetics registration and not as a guaranteed import timeline. For general-trade import of a finished product, complete the required filing or registration before import, appoint a Domestic Responsible Person, and apply a Chinese label that meets the Cosmetics Labeling Rules. Customs and inspection-quarantine formalities are a separate process. Cross-border e-commerce retail import is a different channel with list, platform and personal-use limits; it is not a blanket “no filing” rule and not a path to unrestricted domestic resale. Prepare a safety assessment that addresses leave-on facial exposure where relevant. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform. After a record is issued, check it on the official NMPA filing query https://hzpba.nmpa.gov.cn/gccx/ and the NMPA data-search page https://datasearch.nmpa.gov.cn/datasearch/home-index.html#category=hzp.
Cautions
Do not market an ordinary cosmetic as a clinic peel or as a device-only professional acid if you intend to sell it as a general cosmetic. Follow the rules in force for professional use and labelling.
Questions we are often asked
Is a 30 percent home peel allowed if I put a warning on it?
Only if the exact substance and concentration are permitted for that cosmetic use under the current technical standards. A warning does not legalize a level that is not allowed.
Does exfoliation require special registration?
No. Exfoliation is an ordinary efficacy. It becomes a special cosmetic only if a special function such as whitening or sun protection is also present, or if the claim is treated as a new efficacy.
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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