An Overview of China’s Sunscreen Market and Regulation

As summer is underway, the sales of sunscreen products are surging. According to Ali Big Data, the sales of sunscreen products on Tmall amounted to nearly one billion Yuan in June, archiving the highest sales in one month in history ^[1].

Sunscreen has been one of the most fast-growing categories in China's cosmetic market for several years and is predicted to keep a steady increase. As 2019-2025 China Cosmetics Market Trends and Strategic Consulting Research Report released by Zhiyan Consulting says: “the global sunscreen cosmetics market will grow at an average annual rate of 5.6%. It is expected that the global market will expand to 81.7 billion yuan in 2020, while the Chinese market will reach 9.9 billion yuan, accounting for 12.2% of the global market” ^[2].

The growing consumption power and consumers' enhancing awareness of sun protection are the main drivers for this fast-growing market. Sunscreen Product Market Research Report shows that 24% of consumers start to use sunscreen products before 18 years old, and 45% of consumers use 2 or 3 units of sunscreen products a year on average. Almost all consumers are satisfied with the sunscreen products they have purchased (only 0.5% aren’t satisfied). 81% of consumers think that they'd like to buy the same sunscreen product multiple times ^[2].

As for channels, online shopping platforms have become one of the consumers' favorite channels to purchase sunscreen products. One thing to notice is that the online and offline performances of sunscreen products at different prices vary. Data from Alibaba online shopping platforms, including Tmall and Taobao, shows that sunscreen products priced from 50 to 100 yuan are the most popular, with sales value accounting for 35.6% and sales quantity accounting for 49.0%. The second popular sunscreen products' price range is 100-200 yuan, with 32.1% sales value and 22.6% sales quantity ^[2]. However, data from Intime Mall (One of the biggest shopping malls in China) shows that the sales of high-end sunscreen products (priced over 400 yuan) accounted for 62.99% ^[3]. These two groups of data prove that Chinese consumers tend to purchase lower-priced sunscreen products online and purchase high-end sunscreen products in the shopping mall.

1. New trends

The rise of niche brands

Like other skincare categories, the sunscreen product market is still dominated by international brands, like Shiseido, L'Oreal, and ANESSA. However, relying on novel marketing strategies like Douyin, some niche brands have gained much traction recently, such as ISDIN from Spain, Mistine from Thailand, RE:CIPE from South Korea. Some domestic brands also performed well in the competition. For example, GOZI uses one single product (Nickname: Little Yellow Hat小黄帽) to go viral online and outperformed many international brands.

Douyin TOP10 sunscreen brands' sales in June^[4]

The demand for new functions of sunscreen products

Single-function sunscreen products can no longer meet the needs of more consumers. 2019-2025 China Cosmetics Market Trends and Strategic Consulting Research Report shows that in addition to the basic function of sun protection, 51% of consumers pay much attention to the moisturizing effect of sunscreen products, and 44% of consumers value the skin nourishing effect [2]. Sunscreens with functions like anti-pollution and anti-blue-light also gain specific attention from consumers.

2. Current Sunscreens Regulations

In China, sunscreen products are classified as special cosmetics, and shall be registered with the National Medical Products Administration (NMPA) before being manufactured or imported. The registration dossier generally includes product formulation information, product testing reports, and safety assessment documentation, among other supporting materials. Upon approval, a registration certificate valid for five years is issued.

Within the regulatory framework for special cosmetics, several key compliance aspects are particularly relevant to sunscreen products, including requirements for UV filter use, claims and labeling, and testing.

UV Filter Use

China adopts a positive list system for UV filters, under which only those included in the list of permitted UV filters specified in the Safety and Technical Standards for Cosmetics (STSC) may be used in cosmetic products. Any UV filter not included in the list shall undergo new cosmetic ingredient (NCI) registration before being used in cosmetic products.

Claims and Labeling

China has established specific requirements for sunscreen efficacy labeling, covering sun protection factor (SPF) and protection factor of UVA (PFA) labeling, and related claims such as water resistance. The applicable requirements are summarized below.

For water-resistant claims, sunscreen cosmetics must meet the applicable testing requirements. Products that have not undergone water resistance testing, or for which the SPF value after bathing decreases by more than 50% compared with the SPF value before bathing, shall not make water-resistant claims. Where water resistance is claimed, both SPF values before and after bathing may be labeled, or only the SPF value after bathing may be labeled. Labeling only the SPF value before bathing is not permitted.

Testing

Sunscreen products in China are subject to comprehensive testing requirements covering microbiological, physicochemical, toxicological, human safety, and efficacy evaluations. The main testing requirements include:

• Microbiological testing: Covers microbiological testing parameters such as aerobic plate count, mold and yeast, thermotolerant coliform bacteria, Pseudomonas aeruginosa, and Staphylococcus aureus;

• Physicochemical testing: Focuses on product quality and ingredient-related risks, including heavy metals, UV filters, and other risk substances, with specific items determined based on the product formulation;

• Toxicological testing: Includes safety evaluations such as irritation, sensitization, and phototoxicity testing, with specific requirements depending on product characteristics, including eye contact potential and whether the product is leave-on or rinse-off;

• Human safety testing: Includes tests such as patch testing to evaluate product tolerability;

• Efficacy testing: Includes sunscreen efficacy evaluations to substantiate sun protection claims.

Testing required for the registration of sunscreen products shall be conducted in accordance with the methods specified in the STSC, and performed by qualified testing institutions recognized by the NMPA.