Hong Kong vs China Cosmetics Import Rules Compared

The biggest difference in Hong Kong vs China cosmetics import rules is pre-market approval. Hong Kong has no registration or notification scheme for ordinary cosmetics and charges no import duty on them.

Mainland China requires every imported cosmetic to be registered (special-use products) or filed (general products) with the National Medical Products Administration (NMPA) before import, carry a Chinese label and pass import inspection.

So a shipment that is ready for Hong Kong is not automatically ready for the mainland. The table below summarises both systems from the legal texts.

Hong Kong vs China cosmetics import rules: comparison table

Swipe sideways to see the whole table.

Pre-market approval is the main dividing line

Article 4 of the mainland regulations splits cosmetics into special and general products: special products are registered, general products are filed.

Article 16 lists the special categories, and Article 17 states that special cosmetics may be produced or imported only after NMPA registration, while imported general cosmetics must be filed with NMPA before import.

Article 23 requires an overseas registrant or filer to appoint an enterprise legal person inside China. Article 19 lists the dossier, including proof that the product is already sold in its country of manufacture and evidence that the overseas factory follows good manufacturing practice.

Hong Kong takes a different approach. According to a 2018 Legislative Council reply (LCQ14), cosmetics not covered by other laws fall under the Consumer Goods Safety Ordinance, and Customs refers to reasonable standards such as those of the EU, the US and the mainland when it checks products.

There is no filing step before sale. The exception is a product that counts as a pharmaceutical product under the Pharmacy and Poisons Ordinance (Cap. 138)⁵, which must be registered before it is sold.

Labels: bilingual warnings in Hong Kong, full Chinese label on the mainland

Section 2 of Cap. 456A says that any warning or caution about the safe keeping, use or disposal of consumer goods must be in both English and Chinese. A Korean product with a Korean and English label can be sold in Hong Kong, but if it carries a caution, a Chinese version is needed as well.

On the mainland, Article 35 of the regulations and Article 6 of the Cosmetics Labelling Measures (in force for new registrations and filings from 1 May 2022) require a Chinese label. An added Chinese sticker is accepted, but its safety and efficacy content must match the original label.

Taxes and paperwork

Hong Kong Customs lists only four kinds of dutiable commodities: liquor, tobacco, certain hydrocarbon oils and methyl alcohol. Cosmetics are not among them. Importers still lodge an import declaration within 14 days under the Import and Export (Registration) Regulations (Cap. 60E)⁶.

On the mainland, Article 10 of the VAT Law (in force 1 January 2026) sets 13% for imported goods, and Article 14 builds the taxable value from the customs value plus customs duty and consumption tax.

What this means for buyers

• Selling in Hong Kong: check bilingual cautions, keep proof of origin and supply, and file the trade declaration.
• Selling through formal mainland channels: first confirm that the brand has NMPA registration or filing and who its responsible enterprise in China is. Without it, a mainland importer cannot bring the goods in.
• SEONGWOO GLOBAL operates a Seoul company and a Hong Kong company, SEONGWOO GLOBAL LIMITED (BR 81375387), so it can contract under Hong Kong rules.

Sources

• Regulations on the Supervision and Administration of Cosmetics (gov.cn): https://www.gov.cn/zhengce/content/2020-06/29/content_5522593.htm
• NMPA Announcement 2021 No. 77, Cosmetics Labelling Measures: https://www.gov.cn/gongbao/content/2021/content_5631831.htm
• VAT Law of the PRC (State Taxation Administration): https://fgk.chinatax.gov.cn/zcfgk/c100009/c5237365/content.html
• Hong Kong Cap. 456A: https://www.elegislation.gov.hk/hk/cap456A!en and Cap. 60E: https://www.elegislation.gov.hk/hk/cap60E!en
• Hong Kong Customs, dutiable commodities: https://www.customs.gov.hk/en/service-enforcement-information/cargo-clearance/dutiable-commodities/index.html
• LegCo reply LCQ14 (2018): https://www.info.gov.hk/gia/general/201806/27/P2018062700331.htm

Related reading: How to import cosmetics into Hong Kong · Hong Kong cosmetics labelling · Re-export via Hong Kong

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