China Import Requirements Overview for Japan-Origin Products

China cosmetics: NMPA filed vs registered

Under the Cosmetic Supervision and Administration Regulation (CSAR), cosmetics for the Chinese market are divided into two categories:

• Special cosmetics (特殊化妆品). Hair dye, hair perm, freckle whitening, sunscreen, anti-hair-loss, and new cosmetic ingredients. Require pre-market registration with NMPA, including efficacy evaluation, safety assessment, and (for some categories) toxicology testing. Timelines: typically 6–18 months from dossier completion to approval.
• General cosmetics (普通化妆品). All other cosmetics. Require pre-market filing (notification) with NMPA. Filing is confirmed within 5 working days; substantive technical documentation must be on file for post-market review.

For both categories, a Chinese-domiciled Responsible Person is required to file or register on behalf of the foreign brand. The Responsible Person can be a brand subsidiary, a distributor, or a specialist agent. Animal testing is no longer mandatory for general cosmetics imported under the post-2021 framework where the necessary exemption conditions (Chinese-issued GMP certificate for the overseas manufacturer, etc.) are met.

China food and supplements: GACC registration

Under GACC Decree 248 (2022), overseas food manufacturers exporting to China must be registered with GACC, with the registration tied to specific product categories. Decree 249 sets out the import administration framework. Practical points:

• Manufacturer registration is by category. A Japanese OEM factory exporting both confectionery and beverages to China needs registration covering both categories. Registration is applied through the Japanese competent authority (MAFF or MHLW depending on category) on behalf of the factory.
• Importer record-keeping. The China-based importer must maintain inbound product records and provide traceability documentation. Random inspection is routine.
• Chinese labelling. Mandatory Chinese-language labelling for retail-channel imports. Pre-shipment label approval is common in practice but is not a formal authorisation step.
• Health food (保健食品).Functional health food requires NMPA approval with efficacy evidence — a significantly heavier process than general food. Some imported categories follow the "filing" (备案) track, others require full registration (注册). Confirm the status of each ingredient before designing the dossier.
• Infant formula and special medical food.Subject to separate, more stringent registration regimes. Outside scope of most overseas OEM brands unless specifically formulated.

Cross-border e-commerce (CBEC) — the parallel track

For brands selling directly to Chinese consumers through approved CBEC platforms (Tmall Global, JD Worldwide, Kaola, etc.) and bonded warehouses, a lighter regulatory track applies. Key points:

• Most cosmetics, most general food, and many health-food categories are on the CBEC positive list and can be sold without full NMPA / GACC pre-market registration.
• Chinese-language labelling is not required on the physical product; the platform shows a translation.
• The CBEC channel is designed for consumer purchases — wholesale and B2B sales remain subject to the general-trade regime.
• The Ministry of Commerce, GACC, and the Ministry of Finance periodically update the CBEC positive list and the cross-border tax framework. Brands relying on CBEC should track the official notices.

Customs and origin

• GACC declaration. The Chinese importer files the customs declaration. Tariffs are based on the China HS schedule.
• China–Japan trade agreements. The Regional Comprehensive Economic Partnership (RCEP) provides preferential tariffs for many Japan-origin products entering China. Origin certification through JCCI or under self-declaration where eligible.
• Import VAT and consumption tax. 13% import VAT (reduced rates for some food categories); consumption tax applies to some cosmetics categories (notably high-end cosmetics historically subject to a luxury consumption tax, modified in recent reforms).

Practical sequencing for Japan-origin China launch

1. Decide on the channel: general trade (retail registration) or CBEC (lighter pre-market burden, but only B2C).
2. For general trade cosmetics: appoint a Chinese Responsible Person, classify the product as special or general, prepare dossier, file with NMPA.
3. For general trade food: confirm GACC manufacturer registration covers the product category; prepare Chinese-language labels including all mandatory particulars.
4. For health food: confirm registration vs filing path; allow 12–24 months for registered health food.
5. Apply for RCEP preferential origin documentation through JCCI.
6. Ship to the Chinese importer; GACC declaration filed; goods released after customs and (if applicable) inspection clearance.