Sunscreen is a special cosmetic
Products claiming sunscreen function fall into the special cosmetics category, which requires registration with the National Medical Products Administration rather than the simpler filing route used for ordinary cosmetics. Registration involves submission of the formula, safety assessment, efficacy testing data, and manufacturing information.
Special cosmetics registration certificates have a validity period and must be renewed. The registration holder must be a legal entity established in China — which is why brands entering the Chinese market typically need a domestic entity or an appointed agent.
Ingredient compliance
Ingredients must appear in the Inventory of Existing Cosmetic Ingredients in China (IECIC), or complete new ingredient registration. Zinc oxide is listed. Where the material is nano-scale, additional documentation on particle characterisation is required as part of the safety assessment.
Safety assessment was historically performed by a licensed assessor; the current framework moves responsibility for the assessment onto the registrant, with a qualified safety assessor signing off. This raised the documentation burden on the technical file considerably.
The practical advantage of being here
For a China-market project, working with a domestic manufacturer removes an entire layer of friction: the entity exists, the manufacturing information is already in the format the NMPA expects, and inspection is a domestic process rather than a cross-border one.
For an export project the situation reverses — the brand holds the authorisation in its own market, and our role is to supply the technical file that supports it.
Described for orientation. Confirm current requirements with a qualified regulatory affairs professional before filing.