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Guide

Are “cosmeceutical” or “medical skincare” products allowed for export to China?

China does not allow you to export a product as a “cosmeceutical” or “medical skincare” category of its own. Under the Cosmetics Supervision and Administration Regulation, a cosmetic is not a product whose purpose is to treat disease. If the item is a cosmetic, it is filed or registered according to its function and it cannot claim medical effects. If it is a drug or medical device, it must follow those regimes instead. Overseas “dermocosmetic” branding does not create a third path.

How to judge the path

Words such as “clinical,” “hospital formula,” “prescription strength” or “treats dermatitis” are high-risk on a cosmetic label. See claims that are often not allowed and the cosmetic–drug border.

A gentle moisturizer used in a dermatology clinic can still be an ordinary cosmetic if that is its true intended use and claims.

Typical documents, tests and labels

Choose one honest path and prepare that dossier. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform.

Cautions

Do not imply that cosmetic filing or registration is medical or drug approval. Those procedures are not a drug-approval process.

Questions we are often asked

Can I keep the word “medical” in the brand name?

A name that claims a medical effect or misleads consumers about the product class is likely to be non-compliant. Review the Chinese name against the Labeling Rules rather than copying the overseas brand line.

Are products sold only in pharmacies automatically drugs?

No. Pharmacy distribution does not by itself change a cosmetic into a drug, and it does not exempt a drug-like product from drug rules.

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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