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Guide
If a BB or CC cream also claims SPF, is it filed or registered?
If a BB or CC cream claims SPF or is used for sun protection, it is registered as a sunscreen special cosmetic. It is not filed as ordinary makeup. The about 10–20 day ordinary-filing cycle does not apply. If the same cream also claims whitening, prepare both special-function evidence packages.
How to judge the path
BB and CC are marketing names. China reads the sun-protection function and the labelled SPF or PA value.
Tone-up language should be checked against whitening classification, especially if it promises a lasting lighter skin tone rather than temporary makeup covering.
Typical documents, tests and labels
Prepare sunscreen registration materials. For sunscreen registration, toxicology testing is about 35 working days, SPF and PA evaluations are about 30 working days each, and review is about 10–12 months after testing is finished. Actual time depends on completeness and supplementary requests. Do not use the about 10–20 day ordinary-filing cycle. 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
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.
A later non-SPF version of the same brand shade is a different product and may be an ordinary cosmetic only if it truly has no sun-protection function.
Questions we are often asked
Does a “light CC veil” without a number still need registration?
If the wording or intended use is still sun protection, assess it as a sunscreen special cosmetic even without a printed SPF number.
Can makeup performance tests replace SPF testing?
No. Wear, shade-match or consumer makeup tests do not replace SPF or PA evaluation required for a sun-protection claim.
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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