2023 JapanThe export growth rate to China reached 18%,but the customs clearance delay rate for depilatory cream products reached as high as 27% — the problem doesn’t lie with "poor quality of the goods",but rather that 90% of agents haven’t fully understood the regulatory boundaries of "special-purpose cosmetics".Last Monday,1,200 tubes of a Japanese brand of depilatory cream owned by a Hangzhou-based cosmetics trader were stuck at Pudong Airport,due to a failure to complete the "import non-special-purpose cosmetics registration" in advance?No,quite the opposite — this product contains "calcium thioglycolate",which belongs to the category of special-purpose cosmetics.Special-purpose cosmeticsWhat is needed is an "administrative licensing approval document",not a filing document.

Hair Removal Cream ≠ Ordinary Cosmetics: 2 Regulatory Boundaries to Clarify

Many agents misunderstand that "depilatory cream is a daily use product" and assume it can be registered as ordinary cosmetics.However,according to the "Regulations on the Hygienic Supervision of Cosmetics","special-purpose cosmetics" include hair growth stimulation,hair dyeing,perming,and depilation,among other nine categories.Depilatory cream,due to its function of "altering the growth state of human hair",clearly falls into the category of special regulatory products.The following table highlights the core regulatory differences between the two types of cosmetics,which directly determine the success or failure of customs clearance:

Japanese depilatory cream: 5-step compliance process (from product selection to customs clearance)

Step 1: Confirm the product attributes - check the ingredient list

Output:

Obtain the product ingredient list from the Japanese manufacturer (which must be available in both Japanese and English versions) and conduct a thorough investigation to determine whether it contains any prohibited substances.Mercaptoacetate,sulfides,and wax derivativesSuch as hair removal active ingredients; if unsure,you can check the regulatory category of similar products through the "National Medical Products Administration Cosmetics Supervision APP" (enter the keyword "hair removal cream" and refer to the product cases that have been approved).

Step 2: Prepare the administrative licensing approval document in advance

Output:

1.Select a third-party institution (such as SGS or Huace) with "cosmetics registration and filing inspection qualifications",and submit 30-50 samples for safety testing (including microbiological testing,heavy metal testing,and skin irritation testing);

2.Entrust a professional agency to submit the "Special Purpose Cosmetics Administrative License Application Form",which requires the following materials: a manufacturer’s authorization letter,product formulation (including raw material sources),a production process flowchart,and a product label draft,among other 12 items (it is recommended to prepare these materials three months in advance).

Step 3: Implement the importer’s qualifications

Output:

Importers must possess the following: 1.A business license (with the scope of business including "cosmetics wholesale") 2.A "cosmetics business registration certificate" (obtained through online processing via the "National Cosmetics Supervision Information Management System") 3.If this is the first import,the importer must complete the "importer registration for imported cosmetics" on the "China International Trade Single Window" platform (upload the business license and contact information; the application will be reviewed and approved within one working day).

Step 4: Book a shipping space and make a declaration

Output:

Select a freight forwarder with "customs clearance experience for special-purpose cosmetics" (required to provide successful case studies from the past six months) and submit the documents to the customs three days in advance:Import Goods Declaration Form,Administrative Approval,Packing list,invoice,contract,and ingredient testing report.

Step 5: Customs clearance and inspection

Output:

Customs Inspection Key Points: 1.Whether the batch number,product name,and ingredient content match the label; 2.The validity period of the test report (must be within 2 years); 3.Whether the goods packaging complies with the “Requirements for Cosmetic Transport Packaging” (e.g.leakproofness,moisture resistance).If any abnormalities are found,additional materials (such as a “Letter of Ingredient Content Description” issued by the manufacturer) must be provided within 48 hours.

Don’t wait until customs clearance to put out the fire: 2 invisible risks that only experienced agents know about

1.Translation Pitfalls of Labels: "Pore Contraction" on Japanese labels cannot be directly translated as "Pore Shrinking"—per "Cosmetic Labeling Regulations," claims must have a scientific basis; if no validation report is provided,suggest translating as "improves pore appearance";

2.Batch traceability risk: The coding rules for the "production batch number" of Japanese manufacturers must be registered with the customs in advance (for example,"L2305" represents production in May 2023),to avoid being classified as "unclear in origin" due to unclear batch number formats (there have been cases where customers’ goods were temporarily detained for 7 days due to inconsistent batch numbers).

3 things you can do today: Avoid falling into traps when importing depilatory creams

• TakeouttheJapanesehairremovalcreamsamplethatiscurrentlyundernegotiationandimmediatelycheckthecontentof"mercaptoacetate"intheingredientlist(anycontentexceeding5%willbedirectlyrejectedforentry);
• Openthe"NationalMedicalProductsAdministrationCosmeticsSupervisionAPP"andcheckwhetherthebrandhasalreadyobtainedanadministrativelicenseapprovaldocumentforsimilarproducts;
• Contactthecooperativefreightforwarderandconfirmwhethertheyhavesuccessfulcasesof"customsclearanceforspecial-purposecosmetics"(andrequestthemtoprovidescreenshotsofthecustomsdeclarationformsfromthepastsixmonths).