Why sunscreen and whitening must be registered, not filed

Sunscreen products and whitening or spot-removal products must be registered because the Cosmetics Supervision and Administration Regulation lists cosmetics used for sun protection and for spot-removal or whitening as special cosmetics. Special cosmetics are subject to registration administration. They cannot be placed on the ordinary-filing path, and they cannot use the about 10–20 day ordinary-filing cycle.

Published 11 November 2026 · Updated 11 November 2026

How to judge the category

Look at the intended use and the labelled claims, including SPF, PA, broad-spectrum, waterproof, whitening or spot-removal statements. A moisturizer that carries an SPF value is still a sunscreen special cosmetic. Physical covering that only makes spots less visible is not the same as a whitening or spot-removal efficacy claim and should not be written as if it were.

What to prepare

Prepare a registration dossier, a full safety assessment, and the required tests. For sunscreen, toxicology is about 35 working days, SPF and PA about 30 working days each, and review about 10–12 months after testing is finished. For whitening or spot-removal, 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.

Cautions

Children’s sunscreen products must also meet the Provisions on Supervision of Children’s Cosmetics. A product that claims both SPF and whitening must carry evidence for both; it is not filed as the “easier” half of the pair.

Questions we are often asked

Can a low SPF still be filed as an ordinary cosmetic?

No. Use for sun protection brings the product into the special-cosmetics category. An SPF value on the label should be supported by the corresponding evaluation and by registration.

Is “brightening” always whitening?

Not every marketing adjective is automatically a legally defined whitening claim, but wording that amounts to spot-removal or whitening will be read that way. Keep the Chinese text aligned with the evaluation you are prepared to submit.