Cosmetics Filing in China: The Complete Step-by-Step Guide

Before We Begin

The first time many brands encounter the cosmetics filing process, they conflate filing with registration, and end up having materials rejected again and again, losing two or three months of launch time unnecessarily. In fact, ordinary cosmetics use a filing system with a clear process and a controllable pace. Get a few key milestones right and the run from document preparation to public disclosure typically takes one to two months. Here is the whole chain broken down.

The conclusion first: for the vast majority of non-special-use cosmetics, what you need is the ordinary cosmetics filing process, not registration. Filing means file first, sell later — once materials are submitted through the NMPA filing information system and public disclosure is complete, the product may be sold, with regulators conducting post-launch checks afterwards. Understanding this makes the logic of every step below fall into place.

I. What Separates Filing from Registration

Simply put, ordinary cosmetics filing covers relatively low-risk categories: most skincare, colour cosmetics and cleansing products. Special cosmetics registration covers sun protection, brightening and spot fading, hair dyeing, perming, anti-hair-loss, spot fading and brightening, and anti-wrinkle claims of special efficacy — these need a special registration certificate before launch. One is a filing system, the other registration: the former is publicised on submission, the latter is reviewed and approved first.

If the product is basic moisturising or cleansing, filing almost always applies. But the moment you claim sun protection or brightening and spot fading, you need registration — the timeline and volume of documentation are entirely different in scale. Guangzhou DEVA Biotechnology has accumulated substantial experience in sun protection and brightening special registration manufacturing; if you need special registration, you can start with our cosmetics ODM services page.

II. The Full Filing Process: Five Stages

Broken into five stages, each with clear deliverables, filing becomes hard to get wrong:

Stage One: Document Preparation (about 1–2 weeks)

This is where things most often stall. Core documents include: the product formula, the product sales packaging (label), the product execution standard (original enterprise standard), safety assessment materials, a brief description of the production process, and the product test report. The formula must list all ingredients and their content, label copy must be compliant and not exaggerate, and the safety assessment report must be issued by qualified personnel. If the documents are messy or incomplete, no amount of speed in the later filing stage will help.

Stage Two: Testing and Toxicology (about 2–4 weeks)

Ordinary cosmetics usually undergo routine microbiological, physicochemical and heavy metal testing. If the formula contains new raw materials or higher-risk ingredients, toxicological testing must be added. Work with a qualified testing body, allow enough samples and time, and do not send samples only just before filing, or the testing timeline will hold everything up.

Stage Three: Filing in the Information System (about 3–5 working days)

Log in to the NMPA ordinary cosmetics filing management system and upload the formula, label, test report and safety assessment as electronic documents. Filing demands consistency across the board — if the label claims, execution standard and formula do not match, the preliminary review or the later inspection will easily surface problems. This stage rewards attention to detail more than any other.

Stage Four: Public Disclosure (on submission)

Once the documents are accepted, the product information is published on the filing platform, and the filing number obtained means the product may be sold. Note that public disclosure does not mean approved — it only means the product is now on the regulator's radar, and post-launch checks can come at any time.

Stage Five: Post-Market Checks (within 3–6 months of launch)

Regulators sample filed materials to verify authenticity, label compliance and test validity. Solid documentation means no cause for worry; if selected and problems are found, you may face an order to rectify or even have the filing cancelled.

Timing Note

Of the five stages, document preparation and testing create the biggest gap. With complete documents and samples sent early, the fastest filing yields a filing number within a month; with repeated document supplements and waiting on test reports, three months is entirely common.

III. How Long Filing Actually Takes

A realistic reference timeline: document preparation 1–2 weeks, testing 2–4 weeks, system filing 3–5 working days, public disclosure immediate, post-launch checks at random after launch. In other words, from starting to receiving the filing number takes 4–8 weeks if things go well. Adding the waiting time for test reports, the industry generally plans on 1–3 months to be safe. Special registration products are outside this table — those run on a timeline measured in months or even years.

IV. How Brands and Manufacturers Work Together

Filing is not one-sided work by either the brand or the factory. A clear division of labour is what makes it efficient:

• Brand (domestic responsible person): responsible for overall compliance, providing the formulation direction and draft packaging copy, confirming the product execution standard, designating the safety assessment lead, and finally submitting the filing in the system.
• Manufacturer (production enterprise): provides genuine production process records, release test reports and production qualification documents, supplies compliance certificates for the raw materials in the formula, and is responsible for the authenticity of the production side.
• Handover points: label copy (claim wording), formula list and test report must all match — this is where things most often go wrong, so align in advance.

Choosing an experienced manufacturer saves a great deal of communication cost. ODM companies like DEVA INTERNATIONAL, focused on fresh-active efficacy cosmetics for nearly 20 years, have ready-made systems spanning formulation and special registration, which makes filing for categories such as baby-and-child skincare smoother. There is also related content on the site covering clean production and efficacy validation.

[Prohibited] Four Common Reasons for Rejection

1. Non-compliant label claims — using medical terms such as anti-inflammatory or treatment, or efficacy claims with no supporting basis.

2. Formula and label mismatch — missing or incorrect ingredients in the list, or contents that do not match.

3. Safety assessment as a formality — the assessor does not meet qualification requirements, or risk substances are not identified.

4. Expired test reports or unqualified testing bodies — confirm the body's qualifications and the report's validity before submitting samples.

V. FAQ

Q1: Can the formula be changed after filing?

Yes, but it counts as a change filing requiring resubmission of change documents. If safety is affected, re-evaluate before making the change.

Q2: Is filing for imported ordinary cosmetics the same?

The process is similar, but it must be handled by a domestic responsible person, and the materials must be translated into Chinese and notarised, so the timeline is slightly longer.

Q3: How soon can the filing number be found?

It is generated once public disclosure is complete and can be checked publicly on the NMPA filing platform. Brands can also display it on their own site as evidence of compliance.

Q4: If a manufacturer handles the filing, does the brand still bear responsibility?

Yes. The domestic responsible person — usually the brand — bears primary responsibility for the authenticity of filing materials and product safety, so confirm the manufacturer's production qualifications and cooperation capability during selection.

About DEVA INTERNATIONAL

Guangzhou DEVA Biotechnology Co., Ltd. (DEVA INTERNATIONAL) has spent nearly 20 years on the R&D and manufacture of fresh-active efficacy cosmetics. It is a cosmetics ODM company integrating R&D, production and special registration manufacturing, holding a cosmetics production licence and ISO 22716 and GMPC qualifications, able to take on special cosmetics registration manufacturing for sun protection and brightening, and supporting brands expanding into Southeast Asia with its Indonesia plant, BPOM registration and HALAL certification.

For more on products and OEM/ODM services, visit www.txodm.com.