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Guide
If my product has both SPF and whitening claims, how do I export it to China?
If a product claims both SPF or another sun-protection function and whitening or spot-removal, it remains a special cosmetic and must be registered. You cannot split the product into an ordinary filing for one claim and ignore the other, and you cannot use the about 10–20 day ordinary-filing cycle. Prepare the sunscreen evaluations and the whitening efficacy work that the claims require, then complete registration before general-trade import. 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.
How to judge the path
Read the whole label, including SPF numbers, PA ratings, “tone-up,” “whitening,” spot-fading language and Chinese translations. The combination does not create a third, easier category.
See also which category applies when a product claims both SPF and whitening. The practical consequence is a single special-cosmetics registration supported by both claim packages.
Typical documents, tests and labels
Plan sunscreen testing (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.) and whitening human efficacy work (For whitening or spot-removal registration, human efficacy method I is about 6 months and method II about 8 months, and review is about 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.) as separate evidence streams in one registration file.
The longer package usually governs the project calendar because registration review begins after the required testing is finished. Jinshang Testing organizes the compliance work. Testing is coordinated with partner laboratories, and those laboratories issue the reports they perform.
Cautions
Do not drop the whitening claim at the last minute without also changing the formula story, name and marketing if those still communicate whitening. Inconsistencies between the label, listings and dossier commonly trigger supplementary requests.
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.
Questions we are often asked
Can I register only the sunscreen part and sell whitening later?
No. What you sell in mainland China should match what was registered. Adding a whitening claim later means changing the registered information or seeking a new registration, following the rules then in force.
Does a tone-up cream with SPF always need both evaluations?
If the product is used for sun protection, register it as a sunscreen special cosmetic and complete SPF or PA work. If the wording also amounts to whitening or spot-removal, prepare that evaluation as well.
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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