Exporting Perfumes to China: Key Compliance and Import Requirements

China's perfume market has been experiencing significant growth. The "2024 China Perfume and Fragrance White Paper", jointly published by Eternal Group, DSM-Firmenich, and Ipsos in September 2024, reveals that the market surged from 11.4 billion yuan in 2018 to 22.9 billion yuan in 2023, achieving a compound annual growth rate (CAGR) of 15%. With projections estimating a rise to 44 billion yuan by 2028 at a 14% CAGR, the sector's long-term growth prospects remain strong.¹

However, challenges persist alongside this expansion. In 2024, the China General Administration of Customs (GACC) rejected 81 batches of imported cosmetics from 18 countries and regions, with perfumes accounting for 11.1% of the rejections.² This underscores the importance of compliance with regulatory requirements for perfume brands targeting China.

In this article, ChemLinked explores the compliance landscape of imported perfumes, focusing on the notification process, as well as customs and import declaration requirements.

Regulatory Compliance for Perfumes

1. General Notification Requirements 

As general cosmetics, perfumes are subject to notification under China's cosmetics regulatory framework. To initiate the process, overseas perfume notifiers shall designate an enterprise legal person within China as the Chinese domestic responsible person (RP) to handle the notification. The RP shall first apply for a user account, and obtain user permission from the cosmetic notification platform. Once granted, the required product testing should be arranged. When all notification documents are prepared, the RP shall submit them through the platform, then the notification is considered complete upon the submission of all required dossiers.

The table below lists the required documents for account application, user permission approval, and notification submission: 

2. Key Considerations for Perfume Notification

As a product primarily composed of fragrance compounds and solvents, perfume requires attention to the following two points in the notification process:

1) The Filling of Product Formula

When filling in the product formula, fragrance can be specified in two ways, with the corresponding documents submitted accordingly:

1. If only "fragrance" is listed as an ingredient in the product formula table, there is no need to provide details on the specific fragrance components and their concentrations. However, if the original packaging label of an imported perfume lists specific fragrance components, an explanation should be provided in the remarks column of the formula table.

2. If both "fragrance" and its specific components are listed in the product formula table, documentation from the fragrance manufacturer detailing all fragrance components and their concentrations shall be submitted.

It is important to note that ingredient concentrations in the product formula shall be expressed as mass percent, while solvents on perfume packaging are typically labeled by volume fraction. Companies should ensure accurate conversion to maintain consistency between formula records and packaging.

2) Safety Assessment

The safety assessment of fragrance in the product is based on how the formulation is filled in. Specifically:

1. If only "fragrance" is listed in the product formula table, the fragrance shall be assessed in accordance with the Technical Guidelines for Cosmetic Safety Assessment 2021, or a certification shall be provided to confirm that the fragrance used complies with the guidelines set by the International Fragrance Association (IFRA) or relevant national standards in China;

2. If both "fragrance" and its specific components are listed in the product formula table, a safety assessment shall be conducted for each individual fragrance component.

Additionally, during the safety assessment, products with an ethanol content of ≥75% (w/w) are exempt from microbiological testing. Given that solvents make up the majority of perfumes—typically 75% to 85%, with ethanol being the most common—most perfumes qualify for this exemption.

Customs and Import Declaration Requirements

1. General Requirements

Once the product notification is complete, overseas perfume notifiers can begin exporting their products to China. Distributors or importers in China shall then submit a customs declaration to the local Customs office along with the required documents (details in the next paragraph). Upon receiving the declaration, the local Customs will review the submitted information and conduct inspections, which include on-site inspection, label verification, sampling and retention, as well as laboratory testing. Once the information is verified and the product passes inspection, Customs will issue a Certificate of Inspection and Quarantine of Imported Goods, which is the final requirement for customs clearance.

The Administrative Measures on Inspection and Quarantine of Import and Export Cosmetics outlines the requirements for importing cosmetics to China. As per this document, perfumes being imported for the first time shall have the notification proof, Chinese label sample, as well as the foreign language label and its translation. Additionally, for customs clearance, documents such as the commercial contract, invoice, packing list, and bill of lading shall be prepared.

2. Key Considerations for Importing Perfumes

1) Hazardous Chemicals in Perfume Imports

As previously stated, solvents account for 75% to 85% to the perfume composition, with ethanol, a flammable substance, being the most common. Due to the high concentration of flammable ethanol, perfume is generally classified as a hazardous chemical upon import under the Inventory of Hazardous Chemicals (2015).

When importing hazardous chemicals—such as perfumes—importers shall declare specific details at Customs, including the hazard classification, packing group, UN Dangerous Goods Number, and UN Dangerous Goods Packaging Symbol. In addition, importers shall submit the following documents:

1. Declaration of Conformity for Enterprises Importing Hazardous Chemicals;

2. For products containing inhibitors or stabilizers, a statement specifying the name and quantity of the added inhibitor or stabilizer;

3. Samples of the Chinese hazard label and the Chinese Safety Data Sheet (SDS).

Furthermore, according to the Regulations on the Control Over Safety of Hazardous Chemicals (2013), Customs is responsible for inspecting imported hazardous chemicals. The inspection covers two key aspects, the chemicals themselves and their packaging, as outlined below:

1. For hazardous chemicals, Customs shall verify whether the product's composition, physical and chemical properties, hazard classification, labelling, and SDS comply with China's mandatory national technical standards, relevant international conventions, standards, treaties, and agreements, as well as technical specifications and standards designated by GACC.

2. For packaging, Customs shall check whether the type, symbol, category, specifications, weight, service conditions, and other relevant details comply with the same kinds of regulations mentioned above.

2) Precursor Chemicals in Perfume Imports

Precursor chemicals in China fall under the Regulation on the Administration of Precursor Chemicals, and are classified into three categories. Category I includes key drug-making materials, while Categories II and III cover chemical agents used in drug production.

The Regulation on the Administration of Precursor Chemicals establishes a classified management and licensing system for the production, operation, purchase, transportation, import, and export of precursor chemicals. Enterprises involved in the import or export of precursor chemicals are required to obtain an Import/Export License for Dual-use Items and Technologies. This requirement also applies to mixtures, such as perfumes, that contain precursor chemicals, for which a license shall be applied following applicable regulations.

Some fragrance ingredients used in perfumes are regulated as precursor chemicals in China. Examples include piperonal (CAS No. 120-57-0), safrole (CAS No. 94-59-7), and phenylacetic acid (CAS No. 103-82-2). Therefore, perfume importers are advised to review the latest regulations to identify which precursor chemicals are currently listed, and verify whether their imported perfumes contain any of these chemicals. If so, they shall apply for the import license in advance.

With extensive expertise in perfume notification, REACH24H Consulting Group, ChemLinked's parent company, offers comprehensive compliance solutions for international perfume brands entering the Chinese market. These services include: user account application, product formula and packaging review, product testing, safety assessment reports, notification dossier submission, and follow-up on official review opinions. Additionally, REACH24H provides compliance support for preparing all necessary documentation for the global transportation of perfumes. Feel free to get in touch at [email protected] for further assistance.