Every year, hundreds of foreign brands attempt to enter China's massive consumer market. Many succeed. But too many stumble on avoidable compliance mistakes — mistakes that result in fines, product seizures, import bans, and damaged reputations.
We've analysed real enforcement cases from Chinese regulators to identify the seven most common — and costly — mistakes. Each one is preventable with proper preparation.
Assuming Your Home-Country Approval Applies in China
EU approval ≠ China approval. FDA clearance ≠ NMPA clearance. This is the single most dangerous assumption foreign brands make.
China has its own regulatory system, and it doesn't automatically recognise foreign certifications. A product legally sold across Europe can be completely banned in China.
An EU skincare brand's shipment was seized at Shenzhen customs because it contained hydroquinone — a whitening ingredient permitted in EU cosmetics at controlled levels, but completely banned in China. Result: entire shipment destroyed, import license suspended for 3 months.
Screen every ingredient against China's Cosmetics Safety Technical Specifications and banned substances list before manufacturing for the Chinese market. Don't assume anything.
Using Marketing Claims That Require Special Registration
Words like "anti-aging," "whitening," "acne treatment," and "sunscreen" aren't just marketing — they're regulatory triggers in China.
China divides cosmetics into "general" and "special" categories. Special cosmetics require pre-market approval from NMPA, which takes 6-12 months longer and costs significantly more. Many brands don't realise their marketing claims push them into the special category.
A UK skincare brand marketed products with "anti-aging" and "reduces wrinkles" claims on Tmall, but had only completed general cosmetics filing. Result: products removed, ¥300,000 fine, plus ¥80,000 in confiscated profits.
Review all packaging, website copy, and e-commerce listings against China's special cosmetics claim list. If you want to use efficacy claims, budget for special cosmetics registration from the start.
Treating Chinese Labels as "Just a Translation"
Chinese labeling isn't about language — it's about format, content, and placement. Getting it wrong can trigger recalls even when your product is perfectly safe.
Chinese cosmetics labels have specific requirements: ingredient order (by weight), Chinese INCI names (not just translations), net content format, manufacturer information, usage instructions, and mandatory warnings. A label that's "close enough" isn't good enough.
A major international skincare brand had to recall 12,000 units because of labeling errors: ingredient order was wrong, net content used the wrong format, and required warnings were missing. The products were completely safe — the labels weren't. Result: recall costs plus ¥200,000 fine.
Have your Chinese labels reviewed by someone who knows GB 5296.3 (cosmetics labeling standard) inside and out. Don't rely on translation agencies — they translate words, not regulations.
Skipping NMPA Registration for Cross-Border E-Commerce
"But we're selling through Tmall Global — that's cross-border, so we don't need registration, right?" This is a dangerous half-truth.
Cross-border e-commerce (CBEC) does have simplified requirements for some products. But it's not a free pass. Products still need to be on the "positive list," and regulators are increasingly scrutinising CBEC channels. Several platforms have been fined for selling unregistered imports.
A cross-border e-commerce platform was penalised for selling multiple imported cosmetics without NMPA registration, including products from UK, France, and Korea worth over ¥2 million. Result: products confiscated, ¥850,000 fine, platform ordered to rectify.
Even for CBEC, verify your products are on the positive list and meet all requirements. Consider CBEC as a market-testing phase while you complete full registration — not as a permanent workaround.
Using Foreign Certifications Without Chinese Equivalents
"Organic," "natural," "cruelty-free," "dermatologist tested" — these claims mean different things (or nothing) in China unless backed by Chinese-recognised proof.
Your EU organic certification, USDA organic seal, or Leaping Bunny logo doesn't automatically transfer to China. Using these claims without Chinese equivalents can be treated as false advertising.
A natural beauty brand used "organic" and "certified natural" on packaging and marketing materials in China, but had no Chinese-recognised organic certification. Result: ordered to stop advertising, ¥450,000 fine.
Either obtain Chinese organic/natural certification (if available for your product category), or remove these claims from China-market materials. Some claims can be rephrased — "made with organic ingredients" may be acceptable where "organic product" isn't.
Ignoring Post-Market Compliance Obligations
Getting your product registered is the beginning, not the end. China requires ongoing compliance: annual reports, adverse event monitoring, label updates, and more.
Many brands treat registration as a one-time hurdle and ignore post-market requirements. This can result in registration cancellation, inability to import new batches, or penalties during random inspections.
Build ongoing compliance into your operations. Assign someone to monitor regulatory changes, submit required reports, and update registrations when formulations change.
Not Protecting Your Trademark in China First
China uses a "first-to-file" trademark system. If someone else registers your brand name before you do, they own it in China — even if you've used it for decades elsewhere.
Trademark squatting is common. By the time many brands try to enter China, they discover their name is already registered by someone else. Buying it back can cost millions — or be impossible.
Register your trademark in China before you start any market entry activities — before you attend trade shows, before you talk to distributors, before anyone knows you're interested in China. File in both English and Chinese.
Before You Enter China: A Compliance Checklist
Pre-Entry Compliance Checklist
- Trademark registered in China (English + Chinese versions)
- All ingredients screened against China's banned/restricted lists
- Product category confirmed (general vs. special cosmetics)
- Marketing claims reviewed for regulatory triggers
- Chinese labels designed to GB 5296.3 standards
- NMPA registration/filing pathway selected
- Required testing completed at accredited Chinese labs
- Responsible person in China identified
- Post-market compliance plan in place
- Cross-border vs. general trade route decided
The Bottom Line
China's regulatory environment is different — not necessarily harder, but definitely different. The brands that succeed are those that take compliance seriously from day one, not as an afterthought.
Every mistake on this list was made by a real company that probably thought, "We'll figure it out as we go." They figured it out, alright — the expensive way.
You don't have to.