General trade import vs cross-border e-commerce for cosmetics

Q: General trade import vs cross-border e-commerce for cosmetics

General-trade import of cosmetics into mainland China is import of goods: the importer must verify that the product has been registered or filed as required, and customs formalities apply in addition to NMPA procedures. Cross-border e-commerce retail import is a separate channel. Under current retail-import policy, eligible goods sold to consumers for personal use through eligible models may not be required to complete the first-import registration or filing that general trade requires, but that is not a general rule that “cosmetics sold online need no filing,” and those goods are not a basis for unrestricted domestic resale.

Published 11 November 2026 · Updated 11 November 2026

How to judge the path

Use general trade when you want the product to circulate in mainland China as ordinary goods—through distributors, shops or domestic e-commerce listings that sell filed or registered products. In that case, follow the Cosmetics Supervision and Administration Regulation: special cosmetics are registered before production or import; ordinary cosmetics are filed before import.

Use cross-border e-commerce retail import only when the transaction truly fits that model: typically a consumer purchase through an eligible platform, within the cross-border retail import goods list and tax rules, for personal use. Policy documents on improving retail-import supervision describe these goods as being supervised in a manner comparable to personal-use inbound items, with list, transaction and quantity conditions. Platforms also set their own quality and information rules.

What each path usually requires

General trade: NMPA filing or registration, a Domestic Responsible Person for overseas brands, a Chinese label that meets the Cosmetics Labeling Rules, test and safety-assessment materials, and customs declaration, inspection or quarantine as applicable. From the medicines-regulation side, the importer should not import a product that has not completed the required filing or registration.

Cross-border retail import: the product generally needs to be on the current retail-import list, sold through an eligible customs-connected model such as bonded retail import or direct purchase, and limited to personal use. It should still meet origin quality and labelling expectations applicable to that channel, and it cannot be treated as a warehouse of goods for later wholesale into the domestic market.

Cautions

Do not simplify this topic into “CBEC needs no filing.” That sentence hides the personal-use limit, the list requirement, platform rules, and the fact that a later switch to general trade or domestic resale brings NMPA filing or registration back into scope. Products involving other controls, such as certain wildlife-related ingredients, can also be excluded from the retail-import list. If your commercial plan is to build a long-term mainland brand presence, plan the general-trade path rather than relying on retail-import convenience.

Questions we are often asked

If we already sell on a cross-border platform, can we open a domestic store with the same SKU?

A domestic store that sells goods in mainland circulation generally needs the product to have completed NMPA filing or registration. Cross-border retail sales do not automatically create that status.

Are the tax and labelling rules the same?

No. Tax treatment, labelling presentation and customs supervision differ between general-trade goods and cross-border retail-import items. Confirm both the cosmetics rules and the customs/tax rules for the model you actually use.