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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.

幻灯片2-2.pngDouyin 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 regulated as special use cosmetics. Manufacturers/importers of sunscreens shall apply for registration with the National Medical Products Administration prior to manufacture or import. (Click here to see the dossiers and procedures of registration for special use cosmetics)

Permitted UV Filters in Cosmetics

China adopts a positive list to regulate UV filters (click here to see the positive list). Cosmetic companies can only use the 27 UV filters included in the positive list, otherwise, applications will be rejected.

Label Standard

According to the Requirements for Sunscreens Labeling, companies shall follow the rules below to mark the SPF, water resistant and PFA on labels.


Measured Value



SPF < 2

No indication of sun protection effect.

SPF = 2~5

Indication of the actual measured value

SPF = 6~50

The maximum labeling SPF shall be actual measured value; the minimum labeling SPF shall be the smaller number comparing the lower limit of 95% confidence intervals of the actual measured value with the largest integer (less than the actual measured value) of multiple of 5

Measured SPF>50 and the lower limit of 95% confidence intervals of the actual   measured value > 50

Indication of SPF 50+

Measured SPF>50 and the lower limit of 95% confidence intervals of the actual   measured value≤50

The maximum labeling SPF shall be “SPF 50+”, the minimum labeling SPF shall be the lower limit of 95% confidence intervals of the actual measured value.


PFA < 2

No indication of UVA protection effect

PFA = 2~3

Indication of PA+

PFA = 4~7

Indication of PA++

PFA = 8~15

Indication of PA+++


Indication of PA++++

Sunscreen   Water Resistant Performance

Sunscreens claiming “water resistant” can be marked with both measured SPF after bath and SPF before bath, or only SPF after bath. Only indication of SPF before bath is not permitted.

“Water resistant” can't be claimed if SPF   after bath decreases 50 percent or higher compared to SPF before bath or products haven't been determined by water resistant performance test.

For the determination methods of SPF, sunscreen water resistance performance and PFA, please refer to Safety and Technical Standards for Cosmetics 2015.

In addition, If the measured value of imported sunscreens in the domestic testing institutions is inconsistent with that on the original packaging, companies shall

  1. add an explanation on the Chinese label if the domestic measured value is bigger

  2. provide a new packaging designed specifically for China and modify the sunscreen protection value if the domestic measured value is smaller. 


According to the Working Rules for Cosmetic Registration and Filing Testing released on Sep 10, 2019, overseas sun protection testing reports will not be accepted for registration. Importers must select a domestic institution to conduct the testing. NMPA has established a cosmetic registration and filing testing information management system ( Importers can search the information of all testing institutions and choose one to conduct their testing via the system. Additionally, testing applications shall be all submitted and accepted online.

The whole testing period of sunscreen is around 8-10 months. The mandatory testing items for sunscreens are also specified in the Working Rules. What should be noted is that the quantitative detection of sunscreens shall focus on the content of chemical sunscreens.

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