How a China launch actually runs.

A product counts as a cosmetic in China only if all three elements hold: applied by rubbing or spraying, to a human body surface, for cleansing, protection, beautification or modification.

Perfume qualifies, so it is an ordinary cosmetic and must be filed with the NMPA before import. A diffuser, room spray or candle fails the body-surface element and needs no filing — until its label says it can go on skin. Claims move it too: "repels mosquitoes" becomes a pesticide, "antibacterial" a disinfection product, and whitening claims, including purely physical coverage, make skincare a special cosmetic requiring registration. Which side each SKU sits on turns on label and claim; send us the range and we will tell you.

Since 1 May 2021 an imported ordinary cosmetic can be exempted from submitting a toxicological test report — what is waived is the report, not animal testing itself.

Two conditions must both hold: the manufacturer holds a quality-management-system certification issued by the government authority of its own country, and the safety assessment fully establishes the product's safety. Products for infants and children, products using a new ingredient still under safety monitoring, and companies flagged for priority supervision are excluded. NMPA Announcement No. 70 of 2026, in force since 28 July 2026, extended the exemption to ordinary cosmetics that do use new ingredients.

The registrant named on the filing is the overseas brand owner itself; the domestic responsible person is a Chinese legal entity that files in the name of that registrant.

Under Article 8 of the Measures for Cosmetic Registration and Filing it submits the filing, assists with adverse-reaction monitoring and recalls, and carries the quality-safety liability set out in its agreement with the brand. It is an agent, not the holder. Whether that entity should be us or a China company of your own is worth settling before the first filing rather than after.

Cross-border e-commerce retail imports, customs codes 1210 and 9610, are supervised as goods for personal use and are not subject to first-import approval, registration or filing requirements.

Perfume, skincare, candles, incense and room deodorisers all sit on the positive list, none of them restricted to bonded mode. The cost is real: personal use only, no resale, no physical retail, per-order and annual value caps, pilot cities only. General trade requires the filing first and, from 1 December 2026, customs verifies it by automatic data matching under GACC Decree No. 284 — in exchange the goods can be sold through any channel in China. Which fits your range is worth an hour.

Five categories of material are needed before an import filing can be submitted: the notarised authorisation, the full formula and ingredient list, the manufacturer's government-issued GMP certification, the safety assessment, and labelling with its claim substantiation.

That GMP certificate must come from the government authority of the manufacturer's own country rather than a private certifier, and it is the step nobody in the room controls. Filing carries no statutory deadline in Chinese law, so a fixed number of working days is somebody's experience, not a rule. A first-launch declaration can now replace proof of sale abroad.

Eight headings recur in an exclusive China agreement: exclusive scope, channel restrictions, minimum purchase, trademark and filing-subject ownership, pricing and discount approval, marketing-cost sharing, trademark registration and enforcement support, and term and exit.

None of them are numbers you can look up — they are the questions to negotiate under. Registration and enforcement of your marks in China can be run on your behalf, with the registration standing in an entity you nominate. Pricing approval and marketing-cost sharing are the two that most often stall a deal, because they settle who carries a slow first year.

Goods are bought outright rather than taken on consignment, so title, inventory risk and the cost of a slow season sit on the China side and not with the brand.

That changes what each party is exposed to. Under a buy-out the brand invoices once and is paid on agreed terms running from dispatch out of its own warehouse, while forecasting, stock cover and markdown decisions move across. Under consignment the brand keeps title and the risk and is paid on sell-through. The payment terms attached to buying outright are the part worth walking through early.

Four channel groups carry niche fragrance in China: offline concept and department retail, platform e-commerce, content platforms, and private-domain membership.

Offline is where discovery happens — department retail such as SKP and Lane Crawford, concept retail such as Tsutaya Books, city'super and AFIONA. Platform e-commerce means a Tmall or JD flagship, run cross-border or under general trade. Content platforms, RED and Douyin, carry the seeding and livestream layer that makes the first two convert. Private domain is WeChat mini-programmes and member communities, where repeat purchase lives. The brands we represent reach that offline layer through our strategic retail partner HARMAY, with 30+ stores, and the Tmall Fragrance stores.

The trademark stays with the brand throughout: any China registration is made in the name of an entity the brand nominates, and what the agreement grants is a licence to use it.

Recommended retail prices for China are set against your official pricing and what the market bears, then go back to you for review before anything is published. Chinese-language content and visuals are produced here and stay subject to your approval. What gets delegated is execution — importing, filing, channel management — not ownership.

The filing names the brand and not its agent, so ending a distribution relationship does not put a China registration at risk.

Since 28 July 2026, changing the domestic responsible person no longer requires the outgoing one's stamped consent: NMPA Announcement No. 70 removed that requirement, leaving a notarised authorisation, the product list and an undertaking. Anything written before July 2026 still says otherwise. Agreements run for a fixed initial term with renewal, and the mechanics of a wind-down belong in the contract itself.

A domestic responsible person has to be a Chinese legal entity, and a retailer will not be yours — nor your importer of record, your customs declarant or your invoicing party.

Those roles have to sit somewhere before a single bottle clears customs. General trade also requires the filing to be complete before import, Chinese labelling to pass customs verification, and settlement in renminbi. And a retailer runs one storefront: nobody is left holding pricing consistent across the others, which is where niche brands lose their positioning fastest.