A Deeper Dive into China’s Animal Testing Exemptions for Cosmetics Imports
May 13, 2021

This March, China’s National Medical Products Administration (NMPA) made headlines when they announced the partial lifting of mandatory pre-market animal testing for imported cosmetics.  Now in May, with the mandate officially enacted, a new pathway has been created for international brands to enter the China market in a cruelty-free manner.

As the second largest beauty & cosmetics market in the world, China is naturally getting all the attention from international cruelty-free brands after this policy change.  These brands must know under what conditions their products are exempt from animal testing and how they may adjust their strategies to introduce products to Chinese consumers.

Here we list a few key questions that determine whether your cruelty-free brand is exempt from animal testing:

  1. Are all imported cosmetic products exempt from animal testing?

As for today, the answer is no.  According to NMPA, the exemption for now applies only to “Non-Special Cosmetics”, which include common cosmetic products such as shampoo, body wash, lipsticks and perfume.   Products that meet one or more of the following conditions are categorized as “Special Cosmetics” and will still be subject to animal testing:

  • Products with special functions such as hair dying, hair perming, anti-freckle, whitening, sunscreen and hair loss prevention;
  • Products with “new efficacies”, for example anti-dandruff (method of determining “new efficacy” is mainly based on “Rules and Categories of Cosmetics Classification” issued by NMPA on July 29, 2020);
  • Products made for infants, children under 12 or pregnant and breastfeeding women;
  • Products using new cosmetics ingredients that are not listed on the Inventory of Existing Cosmetic Ingredients in China (IECIC).


2. What requirements do Non-Special Cosmetics manufacturers need to meet in order to qualify for animal testing exemption?

Companies applying for animal testing exemption must provide the following two documents:

  • A Good Manufacturing Practices (GMP) Certificate
  • A Product Safety Assessment Report 

The required GMP certificate must be issued by a competent authority (not associations) of the country/region where the company is located.  This requirement might create problems for some companies, especially the ones located in the European Union and the United States, where the GMP is not handed out by governmental agencies but by associations or private auditing firms.

In January, France became the first EU country to launch a dedicated digital platform to issue GMP certificates, followed by the UK, who made such function alive recently in May.  However, whilst these platforms had been designed to issue all necessary documents outlined by NMPA, we must wait for the official word from the Chinese government for the validity of these certificates.

3. What type of companies can benefit from the exemption?

Companies that are not categorized as Key Supervision Target (KST) by the Chinese government can benefit from the exemption.  A company becomes a KST when its notifier/responsible/manufacturer has less than or equal to 50 points in the NMPA’s scoring system.  Details of the evaluation method remain to be released yet we know now that the evaluation will be mainly based on conditions such as the company’s quality control and product filing systems.

It is worth noting that once a company gains back enough points (> 50), it is no longer seen as a KST and thus again qualified to apply for an exemption.


4. What market entrance strategy should brands be considering right now?

Up until now, Alibaba’s Tmall Global (TMG) has been the preferred cross-border E-commerce solution for international clean beauty brands to enter China.  The market will continue to evolve as China is stepping away from animal testing requirements but the change will certainly take time.  Meanwhile, TMG remains the primary route for many brands to sell in China.  At the moment, TMG is also taking various initiatives in the beauty & cosmetics category to help promote niche international clean beauty brands.

This latest communication shows China is moving forward in making international cruelty-free beauty & cosmetics brands and their products more widely accessible to the local consumers who are becoming increasingly aware of these topics.  With every policy change, it is certain that these brands can gradually build up their presence in the China market.

About Aventura

Aventura is a China focused E-commerce & Brand Accelerator. Aventura offers holistic solutions to launch, manage and grow businesses in China, drawing upon competences across marketing, sales, e-commerce, and logistics. Founded in 2011, the Group works with a wide range of international consumer brands, start-ups and investors. Aventura is headquartered in Shanghai, with additional offices in Hong Kong and Stockholm.


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