Volume has shifted elsewhere. China supplied 8.1% of US HS 3304 makeup and skincare imports in 2025, down from 18.4% in 2018, but 68.7% of HS 9616 puffs and sprayers (UN Comtrade).
Is China the default source for cosmetics?
No for formulated cosmetics, yes for beauty tools. Cosmetics and personal care manufacturing covers formulated products such as makeup, skincare, hair care, fragrance and oral care (HS chapter 33) and the tools used to apply them, such as brushes and powder puffs (HS 9603 and 9616); China supplied only 8.1% of US imports of makeup and skincare preparations (HS 3304) in 2025, down from 18.4% in 2018, according to UN Comtrade, the United Nations database of national customs trade statistics.
South Korea led US HS 3304 imports in 2025 with 24.8%, followed by Canada (14.4%), France (13.8%) and Italy (12.0%). Worldwide, China made only 5.1% of reported HS 3304 exports in 2023 (US$3.74 billion of US$73.8 billion), and 4.2% of chapter 33 as a whole; France (16.4%), Korea (9.7%), the US (8.5%) and Singapore (7.5%) led.
| HS heading (US imports, Comtrade) | China 2018 | China 2024 | China 2025 | Leader in 2025 |
|---|---|---|---|---|
| 3304 makeup and skincare | 18.4% | 9.1% | 8.1% | Korea 24.8% |
| 3303 perfumes | 2.3% | 0.9% | 1.0% | France 49.0% |
| 3305 hair preparations | 5.7% | 6.1% | 4.9% | Mexico 23.2% |
| 3306 oral hygiene | 18.0% | 21.4% | 18.5% | Mexico 37.5% |
| 3307 shaving, deodorant, bath | 32.2% | 13.1% | 9.4% | Mexico 33.3% |
| 9603 brushes | 71.6% | 65.1% | 55.6% | China |
| 9616 scent sprayers, powder puffs | 59.2% | 69.7% | 68.7% | China |
Two cautions apply. Heading 9603 covers all brushes, not only cosmetic brushes, and the world shares are sums across reporting countries computed from the data, not published by Comtrade. The verdict pill on this page reflects formulated cosmetics; for brushes, puffs and sprayers, China is the default source.
Where cosmetics are made in China: Baiyun and Guangdong
Baiyun District in Guangzhou is the documented center. According to the Baiyun District government, the district had 1,259 licensed cosmetics production enterprises as of July (on a page published in August 2022), equal to 42.07% of Guangdong's total and 23.83% of China's, plus more than 4,200 commercial cosmetics enterprises. That count is likely to have changed since. In April 2025 the district reported more than 550 cosmetics enterprises above designated size in 2024, and more than 90% of its licensed producers sit in four towns and four streets in north Baiyun.
At provincial level, China News Service reported in 2023 that Guangdong's cosmetics output was about RMB 210 billion, roughly 60% of China's total; the year of that figure was not stated. Shanghai, Huzhou in Zhejiang and Yiwu are often cited as other centers, but none was confirmed in an official source for this page.
"Licensed production enterprise" is the unit of count because cosmetics production in China requires a production license administered by the National Medical Products Administration (NMPA) under the 2021 Cosmetic Supervision and Administration Regulation. Whether export-only production needs the same license was not confirmed.
How cosmetics production is organized
Chinese cosmetics manufacturers work under three models:
- OEM: the buyer supplies the formula, and the factory produces it.
- ODM: the factory supplies a stock or modified formula.
- Private label: a stock formula filled into the buyer's packaging.
The minimum order quantity (MOQ, the smallest order a factory will accept) has two parts: the bulk batch size, measured in kilograms, and the minimums for packaging components such as tubes, bottles, pumps and printed cartons. Packaging minimums are often higher than formula minimums. No authoritative benchmark exists, so none is given here.
Lead time runs from formula development and sampling, through stability and compatibility testing, to an ingredient and labeling review against US rules, including FDA color additive approvals (21 CFR Parts 73, 74 and 82) and prohibited and restricted ingredients (21 CFR Part 700). Packaging procurement, meaning the sourcing and purchase of every container and printed component, often sets the critical path. Filling comes last. Before first US distribution, the facility must be registered and the product listed with FDA.
FDA rules under MoCRA
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) added registration, listing, adverse-event and safety-substantiation duties that the US Food and Drug Administration (FDA) enforces for cosmetics. According to FDA's MoCRA page:
- Facility registration. Facilities that manufacture or process cosmetics for the US market, including foreign facilities, must register with FDA and renew every two years.
- Product listing. The responsible person, meaning the manufacturer, packer or distributor named on the label, must list each product and its ingredients and update the listing annually.
- Adverse events. Serious adverse events must be reported within 15 business days.
- Safety substantiation. The responsible person must keep records supporting the product's safety.
- Small-business exemption. Certain small businesses are exempt from GMP, registration and listing, but not for products that contact the eye's mucous membranes, are injected, are for internal use, or alter appearance for more than 24 hours.
Under MoCRA the US brand owner is normally the responsible person, so the brand, not the Chinese factory, lists the product and holds the safety file. The statutory deadline for registration and listing was 29 December 2023; FDA delayed enforcement to 1 July 2024 (88 FR 77323). FDA issued final registration and listing guidance on 12 December 2024 (89 FR 100508), draft records-access guidance on 22 January 2026 (91 FR 2779) and final mandatory-recall guidance on 23 October 2026 (91 FR 66851). Whether foreign facilities must name a US agent was not confirmed from the FDA page.
Two expected rules have not arrived. FDA proposed a talc asbestos-testing rule on 27 December 2024 and withdrew it on 28 November 2025 (90 FR 54603). No proposed or final cosmetic GMP rule was found in a Federal Register search on 30 October 2026.
When a cosmetic is legally a drug
Sunscreens and SPF claims, anti-dandruff products, antiperspirants and fluoride toothpaste are over-the-counter (OTC) drugs in the US, not cosmetics. They require FDA drug establishment registration and drug listing, and the facility pays OMUFA user fees (the FY2025 rates notice is 90 FR 13371). Many private-label skincare orders from China include an SPF product without the buyer realizing that it puts the whole order under drug rules.
Tariff exposure as of October 2026
The MFN duty on HTS 3304.99.50 is Free. As of October 2026, the main additional layer is the 12.5% forced-labor Section 301 duty on Chinese goods, in effect since 24 July 2026. Whether 2018 Section 301 list duties apply to 3304 lines was not confirmed: the List 4A annex excerpt reviewed contained headings 3301, 3302 and 3306 but no 3304 lines. Check each line before quoting a landed cost.
Earlier layers have ended. The Supreme Court struck down the IEEPA tariffs on 20 February 2026 in Learning Resources, Inc. v. Trump, and a 10% Section 122 surcharge applied from 24 February to 24 July 2026.
Common mistakes and how to evaluate a cosmetics factory
- Assuming the factory "handles FDA." The factory registers its facility; the US brand lists the product, keeps the safety file and reports serious adverse events.
- Ordering SPF or medicated products as cosmetics. They are OTC drugs.
- Using colorants permitted in China but not approved by FDA, or uncertified batches where FDA requires certification.
- Underestimating packaging minimums, which often sink small first orders.
- Relying on the small-business exemption for eye-area, injected, internal-use or long-lasting products, which it does not cover.
- Confusing China's domestic rules with export rules. China's animal-testing and NMPA filing rules apply to products sold in China; the export-side position was not confirmed.
Counterfeiting is a real risk in this category. USTR's 2026 Special 301 Report, citing a 2022 OECD-EUIPO study, states that China and Hong Kong accounted for 83% of counterfeit cosmetics customs seizures; that is a secondary citation of 2017–2019 data. In evaluating a factory, confirm its NMPA production license and FDA facility registration, ask who owns the formula, require full ingredient disclosure for US labeling and listing, and confirm that its color additives are on FDA's permitted lists.
Frequently asked questions
Are most cosmetics made in China?
No. China made 5.1% of world exports of makeup and skincare preparations (HS 3304) in 2023 and supplied 8.1% of US imports in that heading in 2025, according to UN Comtrade. South Korea, Canada, France and Italy each supplied more to the US. China does dominate cosmetic brushes and applicators, with 68.7% of US powder-puff and sprayer imports.
Where is China's cosmetics manufacturing hub?
Baiyun District in Guangzhou, Guangdong. According to the Baiyun District government in 2022, it had 1,259 licensed cosmetics production enterprises, 42.07% of Guangdong's total and 23.83% of China's. More than 90% of them sit in north Baiyun. The count is several years old and has likely changed.
Does a Chinese private-label cosmetic need FDA registration?
Yes. Under MoCRA, the manufacturing facility must register with FDA and renew every two years, and the responsible person, usually the US brand, must list the product and its ingredients. FDA's enforcement of registration and listing began on 1 July 2024 (88 FR 77323). SPF and other OTC drug products follow separate drug registration rules.
Does FDA approve cosmetics before sale?
No, apart from color additives. FDA does not pre-approve cosmetic products; this is long-standing FDA policy. MoCRA added facility registration, product listing, serious adverse event reporting within 15 business days and safety substantiation records, but it did not create a pre-market approval system for cosmetics.
Is there an asbestos testing requirement for talc cosmetics?
Not as a final rule. FDA proposed a rule requiring asbestos testing of talc-containing cosmetics on 27 December 2024 and withdrew it on 28 November 2025 for further consideration (90 FR 54603). As of October 2026, no replacement rule had been found in the Federal Register.
What tariff applies to cosmetics from China?
As of October 2026, the MFN duty on HTS 3304.99.50 is Free, and a 12.5% forced-labor Section 301 duty applies to Chinese goods from 24 July 2026. The IEEPA tariffs ended in February 2026. Whether 2018 Section 301 list duties apply to individual chapter 33 lines was not confirmed, so check each line.
Sources
- United Nations Statistics Division (UN Comtrade) — UN Comtrade database, HS 3303-3307, 9603, 9616
- Baiyun District People's Government, Guangzhou — Baiyun cosmetics industry enjoys rapid development
- Office of the United States Trade Representative — 2026 Special 301 Report (citing OECD-EUIPO studies)
- comtradeapi.un.org/public/v1/preview/C/A/HS?period=2023&partnerCode=0&cmdCod…
- en.by.gov.cn/2025-04/22/c_1087597.htm
- fda.gov/cosmetics/cosmetics-laws-regulations/modernization-cosmetics-regulat…
- federalregister.gov/documents/2023/11/09/2023-24731
- federalregister.gov/documents/2025/11/28/2025-21407