Who should be the filer or registrant for imported cosmetics

For imported cosmetics, the filer or registrant is the enterprise or other organization that applies for registration or carries out filing and legally takes responsibility for the product’s quality and safety. In most brand-owned projects that is the overseas brand owner, not the freight forwarder and not automatically the distributor. An overseas filer or registrant must then appoint an enterprise legal person in China as the Domestic Responsible Person.

Published 11 November 2026 · Updated 11 November 2026

How to judge who should file

The Cosmetics Supervision and Administration Regulation requires the applicant or filer to be a duly established enterprise or other organization, to have a quality-management system suited to the products, and to have the ability to monitor and evaluate adverse reactions. Choose the entity that actually controls the formula, claims and post-market duties. A local importer can be that entity if the commercial arrangement truly places those duties on it; otherwise the overseas brand should remain the filer or registrant and authorize a Domestic Responsible Person.

What to prepare

The chosen filer or registrant provides identification and qualification materials on first submission, the product dossier, and the authorization that appoints the Domestic Responsible Person. If several companies share a group relationship or a contract-manufacturing relationship, keep the agreements consistent with the names that will appear on the label and in the system.

Cautions

Do not treat “whoever pays the invoice” as the legal filer. Changing the filer or registrant later is a formal change, not a commercial side letter. Manufacturers remain responsible for producing according to the technical requirements stated in the registration or filing materials, but they do not replace the filer or registrant.

Questions we are often asked

Can our China distributor be the filer?

Yes, if that company is truly taking on the legal role of filer or registrant and meets the qualification conditions. Many brands prefer to remain the filer themselves and appoint a responsible person instead.

Is the factory the registrant?

Usually no. The factory is the manufacturer. It may be the registrant only if it is also the legal applicant that takes quality and safety responsibility.