cosmetics Archives - Focus - China Britain Business Council https://focus.cbbc.org/tag/cosmetics/ FOCUS is the content arm of The China-Britain Business Council Wed, 23 Apr 2025 09:51:11 +0000 en-GB hourly 1 https://wordpress.org/?v=6.9 https://focus.cbbc.org/wp-content/uploads/2020/04/focus-favicon.jpeg cosmetics Archives - Focus - China Britain Business Council https://focus.cbbc.org/tag/cosmetics/ 32 32 Can Chinese beauty brands succeed abroad? https://focus.cbbc.org/can-chinese-beauty-brands-succeed-abroad/ Mon, 17 Jul 2023 06:30:39 +0000 https://focus.cbbc.org/?p=12768 A trending social media makeup style is achieving the level of international soft-power cultural influence that decades of political manoeuvring never could. As Tong Global explain in an article originally published in their latest market analysis paper, STYLE 容, ‘Douyin Makeup’ has a lot to teach us about the international expansion of Chinese beauty brands “I’m sorry, but what is this?” – so goes the catchphrase of Mirta Miler, also…

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A trending social media makeup style is achieving the level of international soft-power cultural influence that decades of political manoeuvring never could. As Tong Global explain in an article originally published in their latest market analysis paper, STYLE 容, ‘Douyin Makeup’ has a lot to teach us about the international expansion of Chinese beauty brands

“I’m sorry, but what is this?” – so goes the catchphrase of Mirta Miler, also known as Mimiermakeup, a top international beauty influencer who shares snappy one-minute videos showcasing various makeup trends to her 17.5 million TikTok followers. In this particular post, the 25-year-old Croatian content creator gestures in mock disbelief to a beautifully lit selfie of a young Chinese woman’s impeccably made-up face. “It’s a work of art!” she exclaims, with the overdramatic flair that has made her a celebrity of the global BeautyTok community, “I just need to try it on my face!” A series of subsequent quickly-cut clips depict the many products and steps being applied. “The Douyin makeup girlies’ skin is always super glowy,” she observes while patting her cheeks with a dewy moisturising primer from SheGlam – a cosmetics brand launched by globalised Chinese e-commerce giant Shein – to emulate the look.

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This is the first C-Beauty trend to go viral overseas. C-Beauty stands for Chinese Beauty, and its growth follows a wave of interest in J-Beauty (Japanese) and K-Beauty (Korean) brands over the past 10 years or so. Sales of C-Beauty brands grew by 51% between 2017 and 2022 according to Euromonitor International, outperforming the 42% growth in the market overall. C-beauty brands accounted for 28% of retail sales among the top 20 brands sold in China last year, increasing from 14% in 2017. Popular C-Beauty brands include Florasis, Proya and Perfect Diary. 

The ‘Douyin Makeup’ trend offers the world a window into China’s evolving style culture and its realm of self-expression. Derived from styles popularised by live streamers on Douyin (the domestic Chinese version of TikTok, both owned by Bytedance), this distinctive makeup look is characterised by dramatic eye contouring techniques, glittery luminescent eye-shadow, softly blurred lip colour, generous cheekbone highlighter, and doll-like clusters of long individual false lashes.

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The cultural export of ‘Douyin Makeup’ on social media comes at a time when domestic Chinese cosmetics trends and brands are experiencing a market renaissance as younger users increasingly find style inspiration in their own unique experiences, heritage, local culture and media. Many are turning away from the now-outdated notion that ‘foreign is better’, a consumer phenomenon often referred to as guochao.

In the beauty space, this delves further than just skin-deep. Cult Chinese brands and products tap into the need for makeup techniques that both complement Asian features and reflect East Asian beauty standards and aspirations, such as more rounded facial structures, glassy skin, unarched brows and bright accentuated eyes.

As consumer priorities and sentiments shift, the market evolves alongside it. The cosmetics and personal care sector, now valued at £35 billion in China, used to be aggressively saturated with Western and international brands, leaving less room for domestic players to grow into, particularly at the premium level. Now, however, domestic startups are flourishing like never before. Driven to innovate and differentiate by the long-established hyper-competition of the space, and riding the wave of a new cultural climate, brands like design-conscious Judy Doll and eco-friendly LAN Time are capturing the zeitgeist.

TikTok user @theoliviasaurusrex tries out a Douyin-inspired look

“[In the past], I had a preference for Korean and Japanese makeup, but now my favourite is Chinese makeup. Chinese brands are doing amazing things, and I want to try every single one,” says Laura, a beauty and lifestyle KOL. “They make cosmetics that are suitable for Chinese people.”

With its glamorous feminine aesthetic, the ‘Douyin Makeup’ look draws considerable inspiration from Chinese television and stage makeup. Stars of contemporary lifestyle TV shows, as well as traditional makeup inspired by dynastical historical dramas, have formed a source of inspiration for Laura and many other makeup fans: “I was first attracted to beauty and makeup from watching TV shows as a kid. I wanted to learn how to do makeup looks just like the characters,” she says.

The specific techniques used in the ‘Douyin Makeup’ trend also reflect a merging of cultural influences, combining Chinese elements like straight ‘skinny’ eyebrows and doll eyes with the gleaming highlighter of Western contouring styles, the exaggerated glitter of music festival looks, and K-Beauty inspired ‘gradient’ lips. This is a telling example of how the guochao craze is not as simply defined as a rejection of global influences in favour of newfound nationalistic fervour.

Rather, it’s an awakening to contemporary Chinese culture and experience taking their own place of prominence alongside globalised trends and influences, driven by the young Chinese who advocate an indigenous personal style that is all their own. “When I apply makeup, I can feel what power or value this style brings to me. Makeup is about empowering self-acceptance and self-recognition,” shares Quinn, a Gen Z content creator.

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Connecting to this consumer mindset has been key for high-growth C-Beauty brands that have captured the market by tapping into cultural trends, an emphasis on creative self-expression, and demand for products which are both high-performing and accessible. Case studies abound, from Colorkey’s playful yet meticulously developed lipstick colours designed specifically to enhance East Asian skin tones, to Florasis’ (花西子) artfully intricate packaging and palettes inspired by imperial Chinese antiques.

Florasis has found success in China and abroad with its Chinese antique-inspired palettes and carved lipsticks (photo captured from Instagram @florasis.official_)

“IN2U, Cai Tang, Colorkey, Flower Knows, Judy Doll; these are all Chinese brands which I love right now. A few years ago, people paid a lot of money for big established brands, but their products aren’t expensive to produce, so you are just paying for the branding,” says Laura. “These new Chinese brands have a lower price, but are also leading the trend in terms of innovation, particularly in cosmetic ingredients and textures.”

There is also a growing wave of cult interest in affordable products that deliver results comparable to high-end skincare or beauty salons. For example, La Terapia (了于) offers haircare specifically for East Asian hair using ancient Chinese hair care practices and cutting-edge biopharma technology. Similarly, TCM-inspired Herborist’s (佰草集) viral-trending Tai Chi face masks contain more than 20 active ingredients from plants.

As ‘Douyin Makeup’ and other C-Beauty influences grow their cultural stature both at home and abroad, it presents an opportunity for Western beauty brands to engage with Chinese consumers in a new light. Authentic representation, cultural fluency, and meeting audiences where they are by embracing and empowering their own trends and tastes; these tenets play a new and defining role in brand acceptance. “I appreciate brands and trends that authentically combine Eastern and Western elements,” says Quinn.

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If trending styles on social media are anything to go by, then it’s clear ‘Douyin Makeup’ is only the tip of the iceberg – a paradigm shift that isn’t fading away anytime soon. Laura shares her predictions for what could be the next big crossover beauty trends: “When I go out at the weekend, I search on Xiaohongshu for trends like tianku [甜酷 ‘sweet & cool’] or yujiefeng [御姐风 ‘queen diva style’] to get inspiration.” A quick Instagram search for ‘Xiaohongshu makeup’ on Instagram also turns up a clutch of Western creators sharing and emulating unique styles found on the Chinese platform.

Xiaohongshu Inspired Springtime Makeup’ is the title of a series of tutorial reels by African-American beauty influencer EssenceElizabeth. In the videos, she cites products from both Western and East Asian brands, tags the Chinese KOL Jellybean_xxdd (老甜 豆儿) whose photo she references, and calls the trend – which features round face contouring, extremely subtle eyebrows and rosy red cheeks – “the prettiest makeup I have ever seen in my life!”

This article was first published in Tong’s latest market analysis paper, STYLE 容. Download the full issue here.

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How a British skincare brand made it big in China https://focus.cbbc.org/how-a-british-skincare-brand-made-it-big-in-china/ Thu, 16 Jun 2022 07:30:01 +0000 https://focus.cbbc.org/?p=10426 Tom Pattinson speaks to Joy Isaacs, founder and CEO of Argentum Apothecary, to find out how changing the company’s China strategy – and offering a local company a minority stake – helped them make the most of their new found popularity in the market Singer Faye Wong is one of China’s most recognisable style icons. Her stratospheric rise in the 1990s as one of China’s first musical superstars made her…

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Tom Pattinson speaks to Joy Isaacs, founder and CEO of Argentum Apothecary, to find out how changing the company’s China strategy – and offering a local company a minority stake – helped them make the most of their new found popularity in the market

Singer Faye Wong is one of China’s most recognisable style icons. Her stratospheric rise in the 1990s as one of China’s first musical superstars made her a household name. Decades after she first rose to fame, hundreds of millions of women across China have wondered how this woman in her early 50s has retained her youthful looks.

All was revealed after her daughter posted a picture to social media of her mother’s dressing table, featuring a mysterious elegant black jar. The little black jar contained an anti-ageing serum by boutique British skincare brand Argentum – and just like that, the company became something of an overnight success in China.

 

“We have a really distinctive black shaped jar that really stood out in the photograph,” explains Argentum’s founder Joy Isaacs. “Suddenly everyone was clamouring to get hold of this product,” she says.

Isaacs’s company uses a patented combination of Silver Hydrosol and DNA HP (thus the Ag in the name) to create natural, restorative and super-hydrating anti-ageing skincare products. The brand has built a strong presence in China, where the demographic of luxury skincare spans a much broader age range, with more and more younger people investing in the future of their skin, says Isaacs. “In China, there is an understanding of silver and a focus on luxury skincare that delivers results. Our formulas score particularly high when targeting acne and blemishes which is a common skin concern in this part of the world.” But the demand created by Wong’s daughter’s social media post took Isaacs by surprise.

“We had two Chinese team members in London and Shanghai who were both helping us work with a number of different distributors in China, [but] it was very hard to align multiple distributors on different platforms and across different regions,” explains Isaacs. This made it difficult to effectively manage the growth they were seeing.

Joy Isaacs, Founder and CEO, Argentum Apothecary

“Large online retailers and cross-border sellers would have as many as 200 authorised resellers, and multi-brand stores would have sub-distributors,” says Isaacs. With so many different resellers, keeping up with pricing and offers was very challenging. Furthermore, UK or Europe-based retailers and distributors would resell to China too.

Sometimes resellers would discount products, not only affecting pricing but also making it difficult to control brand image, a common concern for luxury brands. “Some of our China distributors were investing tens of thousands into a campaign only for it to be undercut by external wholesalers, undermining the whole campaign,” she explains.

Eventually, after a number of meetings and working with one impressive distributor, they decided to create a more permanent partnership, selling a minority stake in the company. Having a local stakeholder means Isaacs and her UK team don’t have to get bogged down navigating regulations and controlling pricing. What’s more, now, “everyone is on the same train and heading in the right direction.”

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“It really has accelerated our growth in China enormously. They have been able to support in registering our products on the ground and growing sales in a sustainable and authentic way. For example, we are launching in China Duty Free, which enables us to sit alongside the biggest international brands,” says Isaacs. “It also enables us to concentrate on our creativity.”

Isaacs has diluted the company by selling a portion to a Chinese distributor and growth accelerator, but, she says, “it was absolutely the right thing to do. When you see what they achieved for our brand in just one year – there is no chance we would have been able to grow this complex and fascinating market alone.”

Call +44 (0)20 7802 2000 or email enquiries@cbbc.org now to find out how CBBC can help you find the perfect partner or supplier to support the growth of your business in China.

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China Consumer 2022: Why is China crazy for beauty samples? https://focus.cbbc.org/china-consumer-2022-why-is-china-crazy-for-beauty-samples/ Wed, 27 Apr 2022 07:30:16 +0000 https://focus.cbbc.org/?p=10059 The beauty industry has long relied on free samples to reach new customers, but they have become even more key to attracting and retaining consumers in China’s crowded beauty market In the West, consumers often ask for samples prior to purchasing an item to try before they buy, whereas in China brands tend to give out samples only once a shopper has purchased a full-sized product. To Chinese consumers, samples…

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The beauty industry has long relied on free samples to reach new customers, but they have become even more key to attracting and retaining consumers in China’s crowded beauty market

In the West, consumers often ask for samples prior to purchasing an item to try before they buy, whereas in China brands tend to give out samples only once a shopper has purchased a full-sized product. To Chinese consumers, samples or gifts are no longer a feel-good treat or an unexpected bonus, but instead have grown to become a key selling point driving consumer behaviour and spending.

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Chinese consumers who regularly visit official branded stores on Tmall or JD will often expect samples to be full-sized, particularly during major retail events such as the annual Double 11 Shopping Festival (also known as Singles Day). High-end brands will often give away a selection of sample-sized products that add up to the volume of a full-sized product. Chinese shoppers may also rate their shopping experience based on the quality of the sample received. This is similar to the “blind box” phenomenon (where consumers purchase a package from a brand containing unknown contents), where the game-like element of opening the boxes stimulates buyer curiosity, and the unwrapping experience is tailor-made for sharing on social media.

The fact that samples are usually only received after the purchase of a full-sized product has created a thriving market of multi-brand sample stores, the most famous of which is Harmay. According to Jing Daily, Harmay was valued at RMB 500 million in early 2021 and has expanded rapidly in recent years, opening branches in major cities including Beijing, Shanghai and Hangzhou. Shopping at Harmay is somewhat of a ‘blind box’ experience; the store doesn’t necessarily always stock the same products or brands, promoting revisits. This appeals to young consumers who are enthusiastic about discovering new products from international brands but may not have the cash to throw away on products they may not like.

Chinese consumers have literally hundreds of consumption channels at their fingertips, leaving them constantly on the lookout for added-value, experiential spending opportunities 

While beauty samples of all kinds are popular, brands should be careful not to underestimate the sample quantity and design detail demanded by Chinese shoppers, so as not to receive negative feedback and damage to brand reputation. Frequent changes to the type or quality of samples offered can also work against brands and reduce profit margins.

Skipping samples completely is a difficult move to make — even if you are not in the beauty sector — as gifting something extra has become a key marketing tool used to tempt new customers, as well as maintain current customers’ loyalty. So think twice when planning your budget for samples, and consider gifting in a sustainable and innovative way to best connect with your Chinese consumers whilst driving your success in-market.

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Is men’s skincare more popular in China? https://focus.cbbc.org/is-mens-skincare-more-popular-in-china/ Fri, 03 Dec 2021 07:30:58 +0000 https://focus.cbbc.org/?p=8797 With purchases of men’s skincare and cosmetics on the rise around the world, but especially in China, RedFern Digital spoke to Jake Xu, founder of skincare brand Shakeup Cosmetics, to find out what works, how live streaming helps, and what to look out for when choosing a trade partner Skincare and cosmetics is a crowded market, but one segment that is still developing is products targeted at men. Many men…

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With purchases of mens skincare and cosmetics on the rise around the world, but especially in China, RedFern Digital spoke to Jake Xu, founder of skincare brand Shakeup Cosmetics, to find out what works, how live streaming helps, and what to look out for when choosing a trade partner

Skincare and cosmetics is a crowded market, but one segment that is still developing is products targeted at men. Many men struggle with finding products that they can relate to and can only identify suitable products through a lot of trial and error or asking shop assistants for help, which they may not feel comfortable doing because of the stigma against using cosmetic products as men.

After working with cosmetic beauty brands at their creative agency, twin brothers Jake Xu and Shane Carnell-Xu realised that they wanted to create a brand of their own that addressed these problems, and Shakeup Cosmetics was born. They worked on the formulation with a UK-based manufacturer and chemist team in 2018, and launched the brand in 2019. Currently in its second year, Shakeup Cosmetics is now growing quickly in both the UK and Chinese markets.

RedFern Digital spoke to Jake Xu in an interview originally published in issue five of China market-focused magazine, The RED Edition.

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Has the stigma around men’s cosmetics and men’s skincare lessened over the past few years?

The stigma is fading, although not as fast as we would like. In the past couple of years, there has been a big shift among men when it comes to finding different ways to express themselves. One method is through using products that allow them to feel confident or good about themselves. A lot of this has to do with mental health, which is a big issue in both the West and in China.

There has been a social shift in how masculinity is defined by individual men. The #metoo movement has shaken many awake, changing the way they think of masculinity, and encouraging guys to start living their own truth. Many men are no longer buying into the previous blueprint of how a man should look or behave.

Another reason is the generational shift. Younger consumers want sustainable products, they want product variety, and they want inclusivity. Although some demand existed previously, its recent growth and popularity has caused brands and retailers to take notice. Additionally, among these newer generations, gender fluidity is more normalised, which is also driving consumer purchasing behaviour.

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Are there any key differences between the men’s cosmetics industry in China and outside of China?

There is definitely a huge difference when it comes to men’s skincare in and outside of China. Countries such as China, Korea and Japan are light years ahead of the West in this category. I think this has been driven by phenomena such as K-pop, Mando-pop and the popularity of ‘xiaoxianrou’ (a term used to describe fresh-faced or young male KOLs in China). By comparison, in the UK, it’s still very much about the more aged-up look, with David Beckham as an example.

When it comes to demographics, Shakeup’s customer base in China tends to be younger than in the West, where a lot of our customers are 35 plus. In China, it is very much the young generation driving demand. Gen-Z consumers purchase more cosmetics and are much more likely to make purchases if they have seen it on Douyin (or it has been recommended by a friend) and it is within their price range.

What trends in men’s skincare are seeing a rise in popularity?

Shakeup Cosmetics focuses on providing products for men that are undetectable when used, so we are currently not looking into developing products such as blushes or eye shadows as we don’t see a demand. The majority of our customers are not looking for that, instead, they want a more natural look. They want to look healthy and have a good, even complexion. Our customers still need education and assistance when it comes to choosing and understanding the purpose of our products.

For our new product development, we focus on ensuring that our products are multifunctional, innovative, and have a great skincare base that provides both long-lasting skincare benefits and the coverage of cosmetics products. Our best product is definitely our BB cream, which is a base product and has been our hero since we launched. Most of our male customers are looking to even out their skin tone and complexion, so products that help with that while remaining undetectable and having a natural finish remain the most popular. Anti-ageing is also a huge concern among customers according to our survey, so it is a function that we are looking to explore.

Which are the most important commercial channels for cosmetics in China, and do you see this changing in the future?

Covid-19 has changed the answer to this question. Online is very important, both in the West and in China. China jumped from being a cash-only society straight to mobile commerce. With this jump, China has also digitised much quicker than other countries. Everybody in China shops online, and even more so since Covid-19 and the lockdown that occurred early on, which allowed online businesses to enjoy a huge boom in the last 18 months.

However, for the cosmetics industry, especially when it comes to skincare and colour, there is still something to be said for the experience of trying it out firsthand. Consumers want to make sure the product is suitable for them or matches their skin tone and are put off by the idea of buying products, having the colour shade be unsuitable for them, then needing to worry about whether the product can be returned. Once consumers have found their perfect product, then repurchasing online is very convenient, with the products delivered directly to the doorstep.  

What has been the impact of live streaming on the men’s cosmetics sector in China?

Live streaming has always been quite popular among Chinese consumers. In China, customers enjoy live streams as a form of entertainment and are more open to streamers promoting products or services during live streams, especially compared to customers in the West, who are more cynical and don’t like advertisements. From that perspective, I don’t think live streams will ever be as successful in the West as they currently are in China, because of the differences in culture and preferences.

We actually just did our first live stream for China with the Chinese actor, model and singer Hu Bing (胡兵). It was a great success commercially as we were in the top three best selling brands of the evening for a good part of the live stream, and we were able to learn a lot. Through this experience, it’s clear that live streaming has huge potential, and we will definitely explore this channel more in the future.

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What mistakes have you seen other brands make when entering the China market?

One of the big mistakes that brands make has to do with finding the right partner for China market entry. A lot of brands choose to work with trade partners or distributors, and since there are so many of them, it can be difficult to choose the right one. Brands can very easily be dazzled by partners, especially ones that are already working with several big brands. Sometimes, brands may choose to work with a trade partner (TP) that is also handling massive global brands in the belief that the TP can elevate their own brand, but then end up having to end that relationship because their brand is too small for the TP to care about or focus on.

Moreover, the strategy for large established brands is very different to small brands, as these bigger brands already have huge demand from consumers. However, new brands need to be more strategic and careful with their market entry and with choosing the right partner. They should assess every aspect of the partnership and obtain references from previous brands that the TP has worked with before committing. Relationships with TPs can be difficult to sever, and the consequences of choosing the wrong one or of not carefully managing that relationship could include losing ownership of the brand’s online flagship store, or even losing the registration of the products in the China market. 

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A guide to the new animal testing and cosmetics laws in China https://focus.cbbc.org/guide-to-new-animal-testing-cosmetics-laws-in-china/ Wed, 04 Aug 2021 07:00:35 +0000 https://focus.cbbc.org/?p=8297 As changes to the laws requiring animal testing for imported cosmetics in China come into effect, RedFern Digital speaks to Mette Knudsen, CEO of certification and regulation compliance company Knudsen & CRC., about the specifics of the changes and the implications for foreign brands looking to tap into the cosmetics market in China – including the new requirement to appoint a liable safety and quality control representative How did the…

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As changes to the laws requiring animal testing for imported cosmetics in China come into effect, RedFern Digital speaks to Mette Knudsen, CEO of certification and regulation compliance company Knudsen & CRC., about the specifics of the changes and the implications for foreign brands looking to tap into the cosmetics market in China – including the new requirement to appoint a liable safety and quality control representative

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How did the Chinese government come to implement these new cosmetic regulations?

In the last 30 years, we have not had any new laws within the cosmetics industry in China, so you can imagine how much of a demand there was for these new regulations. The Chinese government has been working on them for around the last three to four years, developing a novel regulatory framework that is both amazing and really complicated in the sense that there are more safety requirements for the products than in any other market.

Therefore, in June 2020, the State Council announced a new cosmetics regulation called the Cosmetic Supervision and Administration Regulation (CSAR), which came into effect on 1 January 2021. As a follow up to this general regulation, on 4 March 2021, the National Medical Products Administration (NMPA) in China released the Administrative Measures on Cosmetic Registration and Notification, which came into force on 1 May 2021. These new measures officially specify that animal testing will no longer be mandatory for imported cosmetics.

What are the regulations that have replaced animal testing requirements?

When selling imported cosmetics that are not tested on animals in China, the products need to have a Good Manufacturing Practice (GMP) certificate or Quality Management System (QMS) certificate, proving that the cosmetics’ manufacturer has passed Good Manufacturing Practice in their home country. The biggest challenge from this is that the certificate needs to be signed off by the government, rather than by a third party, which is what normally happens in Western countries. Once regular cosmetics brands can show proof of a GMP certificate from their home country that is signed off by the government, then they can generally avoid animal testing when importing into China.

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Regular cosmetics refers to regular skincare and haircare, as opposed to special cosmetics, which could include hair dye, hair perms, anti-freckle and whitening products, sunscreen, and anti-hair loss products. Products for children are also regulated as special cosmetics, for which mandatory animal testing requirements are still in place.

Although this new GMP requirement has caused a lot of headaches, especially among US brands where they don’t have this kind of mechanism in place, it has been a huge game-changer for cruelty-free cosmetics brands as they can now enter the Chinese market.

How do the new cosmetics regulations differ from the previous ones?

One of the main differences is that animal testing was previously mandatory for all imported cosmetics, and now it is no longer required. However, the new regulations also pose some new challenges when it comes to the safeguarding mechanisms that have been put in place. A lot of documentation and information is required from brands regarding both the product and the raw materials used. The reason behind this is because the Chinese government wants to avoid so-called ‘kitchen sink’ cosmetic products, which are products that contain harmful substances such as heavy metals.

Although a lot of documentation is still required, the entire process and uploading of the information can be carried out online, which makes registering much easier.

Although a lot of documentation is still required, the entire process and uploading of the information can be carried out online, which makes registering much easier. As an example, in the past, companies like Knudsen & CRC. would need somewhere between 500-1000 pages of printed paper to complete a single product registration.

What types of documentation are needed for product registration under the new regulations?

The documentation includes qualification documents of the applicant and production entity, basic information about the product, technical and safety reports such as certificates of analysis, testing reports (including on raw materials), or other documents that indicate the products are safe for use.

In addition, new requirements have also been put in place in which brands making efficacy claims about their products must show proof of these claims through documentation. As an example, if a brand says a product provides anti-ageing effects, then this must be proven through scientific literature, human tests, consumer surveys or lab tests.

As you can imagine, this means that the documentation required for product registration under the new laws is massive but will also help to fight against misleading or false product claims among brands.

Are there any other requirements that brands should know about under the new cosmetics regulations?

One of the new requirements of the law is that both the applicant and the entrusted production entity shall appoint a quality and safety person with more than five years of working experience in the cosmetics industry. This person will be responsible for product safety and quality control, quality management supervision, and adverse reaction monitoring and reporting. If something happens in regards to product safety, then this person is responsible and will be liable, directly facing any punishments imposed by the authorities.

For imported cosmetics registrations, the foreign applicant is also required to appoint a responsible agent (legal entity) in China. This China-based legal entity must fulfil several requirements that include having an office, having a cosmetic business scope, and having at least four or five employees. The legal entity will be responsible for cooperating with the supervision and inspection work of the NMPA, marketing communication and advertising compliance, sales and distribution, assisting with product recalls, adverse reaction regular reporting, warehouse control and the handling of customer complaints.

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Can you provide a brief breakdown of the steps that cruelty-free brands should take when entering the China market?

The first step is always to ensure that their trademark has been registered. This is something that we constantly repeat, and yet many brands still don’t do it and then encounter difficulties later because they haven’t protected their trademarks.

The next step is to decide on the owner of the product registration or the responsible person. I would strongly recommend that all brands use the product owner as the owner of the product registration, or at least avoid using the distributor. The reason for this is that the owner of the product registration will have full access to all the information or trade secrets regarding the product formula, production process, and raw material suppliers. We had a very bad case in 2020 where one of our clients provided the product registration to their distributor, who then took everything and copied the product entirely with the information they obtained access to.

I strongly recommend all brands use the product owner as the owner of the product registration, because the owner of the product registration will have full access to all the information or trade secrets regarding the product formula, production process, and raw material suppliers …

The third step is to screen the raw materials. Sometimes brands will use ingredients and raw materials such as probiotics or specific oils that may not be approved in China. In these cases, brands can either decide to re-formulate, to not register in China, or to apply for a new raw material registration, which involves animal testing. As a cruelty-free brand, this may not be an option.

Finally, after determining whether the raw materials are approved in China, the brand will normally decide on the products that they want to register, which is when the actual product registration process begins. Normally,  the products will be registered within four to six months, after which the brand can start selling in China. Under the new law, regular product filings are applicable for life, whereas previously the products needed to be re-filed after four years. Special cosmetic registrations are currently still only valid for five years.

Subtle Energies is a cruelty-free brand that is now being sold at The Peninsula hotels in China

How do you see the new regulations changing the timeline for registration?

With the new online system, I think it will make the time to market much shorter. This is a huge advantage for many cosmetics brands, especially colour cosmetics (i.e., makeup), which are almost like a fashion product where the fashionable colours change rapidly. As a result, the shortened time to market will be hugely beneficial.

Are there any parts of the new cosmetics regulations that you anticipate brands will find difficult or confusing?

I think it depends on where the brand is from. If brands are used to European regulations, they will likely not find it too confusing because the regulations are similar, apart from the need for more documentation. For brands from the US, for example, the documentation requirements may be much more difficult to fulfil because they won’t already have it in hand. The brands will need to go back and test everything for the first time, especially when it comes to the raw materials. The responsible person part of the new regulations may also be a point of confusion because of the number of requirements, even among European brands.

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Are there any categories where you are seeing a particular trend with the types of brands that will be entering the China market after these new cosmetics regulations have come into effect?

There are no specific categories. Every single brand, from low-end and cheaper colour cosmetics to high-end premium skincare will take advantage of these new regulations. China is growing faster than any other market when it comes to cosmetics and will soon to be the biggest market in the world. Most brands don’t have a choice but to look to China, especially with the new lack of need for animal testing. They need to enter the market to be able to compete in the future, which has caused the demand for registration in China to explode.

Do you have a case study that you could provide us with when it comes to importing a cruelty-free brand into China?

As a part of a pilot programme we started in 2018 and that continues to run today, we worked with a number of regular cosmetics brands to launch into China without animal testing. One of these brands is Australian premium skincare brand Subtle Energies, which is currently being sold at The Peninsula Hotel. The brand is Leaping Bunny certified, which is a cruelty-free certification. To import into China through the programme, Subtle Energies needed to comply with cosmetic regulations, such as using only approved raw materials, while also shifting a portion of the manufacturing process into an approved facility within China.

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