Breaking News for Cross-border Sellers: GACC Registration Not Needed in 2025

The Chinese cosmetics market has long been tightly regulated, with strict pre-approval and registration requirements for imported beauty and personal-care products. Under the Cosmetic Supervision and Administration Regulation (CSAR), foreign brands typically must work through a Chinese Responsible Agent to register or file each product with the National Medical Products Administration (NMPA) before launching in China. Special-use cosmetics (sunscreens, hair dyes, whitening products, etc.) require a full registration and technical review, a process that can take many months. Even ordinary cosmetics require a product dossier, Chinese-language labeling, and safety testing by Chinese labs. In short, import/export licensing and NMPA approvals have been mandatory under China’s regulatory framework – until now.

A new 2025 policy update has changed the game for cross-border e-commerce (CBEC) sellers. In the latest draft rules, the General Administration of Customs of China (GACC) has clarified that cosmetics sold via CBEC channels will no longer require GACC facility registration. In practice, this means cosmetics on the official CBEC approved list can be treated as personal-use imports and cleared through customs without the usual registration or certification hurdles. In other words, brands can sell cosmetics via platforms like Tmall Global, JD Worldwide, Xiaohongshu or Douyin without first securing a Chinese “factory license” from customs. This aligns with long-standing CBEC policy – now codified – that CBEC shipments are regulated as “personal articles” and exempt from many pre-import requirements.

Below we explain the old vs. new compliance framework, the implications for international cosmetic brands, and practical tips on strategy and logistics in 2025. We also highlight how companies like GateKaizen (a provider of Chinese market entry, compliance and CBEC strategy services) can help brands capitalize on this regulatory relaxation.

China Cosmetic Regulations: NMPA vs. GACC

China’s cosmetics oversight involves two main agencies. The NMPA (formerly CFDA) handles product safety, ingredient approval, and labeling. Under CSAR (effective 2021), all cosmetics sold in China – domestic or imported – must comply with updated safety standards. Imported cosmetics require either registration (for special-use products) or “filing” (for ordinary cosmetics) with NMPA before market entry. Brands must prepare a full product dossier (formulation, stability tests, toxicology report, efficacy data, etc.), Chinese labels, and often conduct additional testing in China’s designated labs. In short, NMPA enforces product-level regulation: what goes in the product and its claims.

The GACC (General Administration of Customs) – which absorbed the former CIQ – oversees customs clearance and facility registration. Traditionally, any overseas manufacturer or exporter sending goods to China for general trade had to register its production sites with Chinese authorities (historically under AQSIQ’s CIFER system, now under GACC). Decree 248 (2021) requires most foreign food and related exporters to register their factories and even get “official recommendation letters” from their home country if in high-risk categories. Cosmetics were not explicitly listed under those 18 “official” categories, but in practice foreign cosmetics firms often obtained GACC registration/CIFER numbers to smooth customs clearance. At minimum, customs documentation and certificates (health, GMP, free sale) had to accompany general-trade shipments of cosmetics.

Cross-border e-commerce (CBEC) offers a different path. In China’s CBEC model, eligible imported products (on the positive list) are shipped through bonded warehouses or direct mail as “personal use” items. The tax structure is simpler (often VAT/tariffs at reduced rates) and importantly, the full suite of NMPA/CAC approvals is waived. For instance, under the 2019 CBEC rules, “items imported via CBEC are regulated as personal articles, exempt from mandatory licenses, registration or filing requirements”. This has allowed animal-testing-free cosmetics and health supplements to enter China via online channels without going through the lengthy general-trade approval process. In practice, many overseas brands have used CBEC as a “Plan B” to sell cosmetics in China sooner – typically using third-party platforms where a Chinese partner holds inventory in a bonded zone.

The 2025 Update: CBEC Cosmetics Exempt from GACC Registration

The latest GACC draft (2025) makes this CBEC exemption explicit. Article 28 of the revised regulations (for imported goods) states that overseas producers of goods shipped by mail, express delivery, or cross-border e-commerce are exempt from registration. Although that draft explicitly addresses food items, the same principle applies to cosmetics via CBEC: customs will not require cosmetics manufacturers to register or file a CIFER number for CBEC orders. In other words, “GACC registration is not needed” for CBEC cosmetics, which confirms the current informal practice.

This regulatory relaxation echoes China’s broader CBEC strategy of simplified customs clearance and quick market access. As marketing firms note, under “official circulars” CBEC imports (including cosmetics) are treated as personal effects. The practical effect: foreign cosmetics stocked in bonded warehouses or shipped directly can clear customs via the streamlined CBEC channel rather than general trade. For sellers, this means no new import license or GACC facility number is required – brands can export, and customs will release the goods under CBEC rules. (They must still meet product safety standards and supply documentation like invoice, packing list, health certificates as usual.)

In short, for cosmetics on China’s CBEC approved list, the only prerequisites to cross-border sale are:

• Chinese language “e-labels” (or packaging) posted online (instead of paper labels).
• A Chinese importer or agent to handle the CBEC platform interface.
• Basic customs declarations (HS code, product details).
• Compliance with the positive-list ingredient rules and safety standards.

All the usual import/export licensing hurdles – NMPA registration, animal tests, facility registration – are bypassed under the CBEC regime.

Implications for Cosmetic Brands and Compliance

For international brands, this change is a big deal. The burdensome NMPA vs. GACC approvals for cosmetic imports essentially vanish for CBEC sales. Instead of months (or years) of dossier preparation and registration, a brand can list products on a Chinese platform as long as they are on the CBEC positive list. Agencies note that “products imported via the CBEC can be exempt from mandatory requirements, registration, etc.”. Essentially, first-time imported cosmetics via CBEC need not undergo NMPA filing nor customs facility registration.

That said, brands cannot ignore Chinese laws entirely. The exemption applies only to the import licensing process. All CBEC cosmetics must still meet China’s safety and labeling rules. For example:

• Safety and ingredients: The product formula must comply with China’s approved ingredient lists (IECIC), and products must be tested in accredited labs to confirm safety (though animal testing can often be skipped under CBEC for cruelty-free products).
• Labeling and claims: All labels, instructions, and claims must be translated accurately into Chinese, and certain health/efficacy claims require proof. Under CBEC, physical Chinese labels are not strictly mandatory if an e-label is provided, but brands should ensure consumer disclosure (the platform must show Chinese info). Advertising must also comply with Chinese norms – e.g., no unapproved medical claims.
• Platform compliance: CBEC platforms (Tmall Global, JD Worldwide, etc.) have vetting processes. Brands typically need a Chinese compliance partner or agency to list products. Services like GateKaizen can help manage registration of the “Responsible Party” and handle customs paperwork, even if actual product registration is bypassed.

In regulatory terms, the key difference is that CBEC cosmetics are treated like personal imports. Customs will inspect them for safety and correct duties, but will not require the GACC-issued license or NMPA certificate that normal imports need. Industry analysts emphasize that this makes the entry barrier much lower: “first-time CBEC cosmetics can be imported without prior approval or filing” under the special regime.

One practical caution: local customs offices sometimes interpret CBEC rules differently. Official sources (and EU SME Centre guidance) still suggest it’s wise for exporters to begin the registration process “just in case”. In fact, the EU SME Centre notes “although GACC/CIFER registration is not needed… it is recommended that exporters still begin the registration process”. This is mainly to cover any unforeseen audit or if a shipment ends up being treated as general trade. Nevertheless, the 2025 update makes it clear that CBEC sellers have a legal exemption.

Commercial Strategy and Logistics

With registration hurdles eased, brands can focus on market access and logistics. The CBEC channel is ideal for Direct-to-Consumer (DTC) and SME brands testing the Chinese market. Popular cross-border platforms like Alibaba’s Tmall Global, JD Worldwide, Vipshop International, Xiaohongshu, and Douyin Shopping all cater to imported cosmetics. By late 2023, Chinese consumers were buying more cosmetics via CBEC than ever, drawn by the perception of “premium imported quality”.

The government strongly supports CBEC with incentives: higher duty-free thresholds (RMB 5,000 per order), bonded warehouse networks, simplified tax treatment (often VAT/tariff at only 70% of normal rates), and expanding product categories on the import list. Many CBEC pilot zones (Shanghai, Hangzhou, Shenzhen, etc.) offer fast customs clearance. For instance, platforms pre-stock inventory in bonded warehouses to fulfill orders instantly once sold. This means faster customs clearance and delivery to Chinese consumers. Brands can now reach Chinese buyers more quickly than ever by tapping CBEC.

To capitalize, brands should adopt a CBEC strategy:

• Choose the right model: Direct Mail (shipping from abroad per order) or Bonded Warehouse (bulk import to China, then local fulfillment). Bonded warehouses enable faster delivery and larger volumes once stocked.
• Partner with local experts: Entities like GateKaizen can register your Responsible Party in China, help with customs classification, and manage the “e-label” compliance. They also advise on Chinese cosmetic regulations 2025 changes and entry strategy.
• Optimize product mix and pricing: Since CBEC cosmetics can be tax-advantaged, brands can price competitively. Focus on high-demand niches (skincare, cruelty-free beauty, specialized solutions) that Chinese consumers prize.
• Digital marketing: Leverage Chinese e-commerce and social media. Influencer (KOL) partnerships, localized branding, and dynamic content (e.g. Douyin livestreams) are key for CBEC success.

In summary, the regulatory relaxation is an opportunity. CBEC allows companies to sell cosmetics in China faster, without local company setup or heavy bureaucracy. Foreign brands should expedite their China launch plans, using cross-border routes while monitoring any changes. They should also prepare for eventual full market entry: once demand is proven via CBEC, they may decide to register products for domestic sale on local platforms.

Commercial Compliance Tips

• Use China Customs’ CBEC list: Ensure your product HS codes and categories are on the official CBEC positive list. Only those can enter CBEC channels (as defined by MOFCOM, GACC and MOF).
• Quality and Documentation: Even without GACC registration, each shipment must have correct invoices, packing lists, and any required health or safety certificates (ISO, GMP, CPNP equivalents). Customs will inspect for forbidden ingredients or defects.
• Labeling: Prepare Chinese-language labels or at least an e-label PDF. Chinese law technically allows CBEC goods to use an electronic label (accessible online) instead of a pasted one , but customers must be able to see full Chinese info.
• Platform vetting: Platforms often verify your brand and product claims. Be ready to submit your formula, certificates, and marketing claims to the platform auditor.
• Logistics: Work with experienced CBEC logistics providers. They know how to declare CBEC shipments and track them through bonded zones to consumers.

Gate Kaizen and Market Entry Support

Navigating China’s regulatory landscape can be daunting. GateKaizen offers specialized services for global brands entering China’s beauty market. Their experts handle compliance, logistics, CBEC strategy, and Chinese market entry. For example, GateKaizen can advise on label translations and e-certification, coordinate warehousing and customs for cross-border shipments, and plan an omnichannel launch (combining CBEC with future onshore sales). As noted above, while GACC registration is off the table for CBEC, firms still must “bear the main responsibility of quality safety”. GateKaizen helps ensure all such obligations are met.

In practical terms, brands should view this regulatory shift as a green light to accelerate China e-commerce plans. They should still consult local experts (like GateKaizen) to implement a compliant, end-to-end strategy: from selecting the right CBEC platform and logistics model to adapting marketing and customer service for Chinese buyers.

FAQ

• Q: What exactly does “no GACC registration needed” mean?
  • A: It means that cosmetics imported via China’s official CBEC channels are not required to register the overseas manufacturing facility with Chinese customs (the old “CIFER” or GACC factory registration). CBEC imports are treated as personal items, so they skip the usual import licensing/registration regime. In short, you can import on the cross-border list without a GACC registration number.
• Q: Do I still need to register products with the NMPA?
  • A: For CBEC sales only, no NMPA filing is required. Under the special CBEC regulations, imported cosmetics on the positive list do not need premarket registration or filing. However, if you later sell the same product on China’s domestic market (via a local importer or distributor), you must complete NMPA registration/filling and all CSAR requirements.
• Q: Does this apply to all cosmetics and personal care items?
  • A: It applies only to items on China’s CBEC import list and within the policy scope. Generally this includes most makeup, skincare, and bath products that Chinese consumers import via e-commerce. Products like cosmetics for infants or those with novel ingredients still face standard rules even on CBEC. Always check the current CBEC product catalog and confirm with customs.
• Q: Are there any downsides or remaining hurdles?
  • A: Some. Cross-border imports are subject to monthly quotas and a maximum value per order (¥5,000 RMB currently). While the simplified process is attractive, it also means products may not stay in China legally beyond personal use limits. Brands must educate consumers on eligibility and ensure returns/refunds comply with China’s consumer protection laws. Finally, quality and label compliance remain critical – non-compliant goods can still be seized at the border , and platforms can suspend listings for violations.
• Q: How should my brand get started?
  • A: First, confirm your products are on the approved CBEC list and prepare compliant labels/e-labels. Choose a reputable CBEC platform or agency partner. Then work with a service provider (like GateKaizen) to set up your store, integrate customs clearance, and manage local fulfillment. Taking advantage of this change will help you sell cosmetics in China more swiftly and cost-effectively.