As early as 2013, the Chinese cosmetics market jumped to the second place in the world. However, there are still a considerable number of brands that do not use the Chinese market as one of their main battlefields for many reasons (cumbersome licensing procedures, high cost of general trade models, animal experiments, etc.). For these brands, cross-border e-commerce is adopted. The retail model is a good choice to open the Chinese market. In fact, in recent years, many international brands (such as Kiko, Embryolisse) have achieved gratifying success in China by relying solely on imported cross-border e-commerce retail models. Below we will analyze the current policies and regulations of the cross-border e-commerce retail model of imported beauty products and make a simple comparison with other trade models.

Tax advantages of cross-border e-commerce

Cross-border e-commerce retail imports have limits for personal transactions, within which a more favorable comprehensive cross-border e-commerce tax rate (partial reduction of general trade tax, tariff is 0). In 2018, my country increased the single transaction limit from 2,000 yuan to 5,000 yuan, and the annual transaction limit from 20,000 yuan to 26,000 yuan. This is undoubtedly a major good news for beauty products with relatively high customer prices. Attached is the "Notice of the Three Departments Issuing the Improvement of Cross-border E-commerce Retail Import Tax Policies" .

Advantages of cross-border e-commerce filing and approval

Current regulations for cross-border e-commerce retail filing

According to the current regulations on the filing of cross-border e-commerce , the "Announcement on the Supervision of Cross-border E-commerce Retail Import and Export Commodities" , bonded stocking (1210) and collection direct mail (9610) are subject to the supervision of personal imported goods, and relevant products are not implemented for the first time Import license approval, registration or filing requirements. However, the import of products from epidemic areas that have been explicitly suspended by the relevant authorities and emergency response measures for products that present major quality and safety risks are excluded. The advantage of not having to file for the first time allows international brands to sell new products to China in a synchronized global rhythm through the cross-border e-commerce retail model when launching new products.

General trade model filing current regulations

There are relatively strict restrictions on the use of general trade in the sale of cosmetics in my country, and the corresponding filing certificates or administrative license approvals must be obtained for domestic sales (except for cross-border e-commerce retail imports). Imported cosmetics are imported goods subject to statutory inspection, which can enter the domestic market after completing the inspection declaration and customs clearance.

According to the current policy, cosmetics are divided into non-special cosmetics and special cosmetics (hair growth, hair dyeing, perming, hair removal, beauty milk, bodybuilding, deodorization, freckle removal, sun protection). The approval and filing process of imported special cosmetics is generally similar to that of domestic special-purpose cosmetics. The entire process of submitting inspection ➡ declaration ➡ obtaining approval will generally take 7-10 months.

In recent years, the approval of non-special cosmetics has been the highlight of the "separation of licenses and licenses" reform, and it is also a major favorable policy for international brands to enter China. The previous administrative approval model takes about six months to one year from preparing samples, submitting for inspection, preparing application materials after passing the test, formal review, technical review, review decision and obtaining administrative license approval after passing. After the reform of "Separation of Licenses and Licenses", the procedures for submitting inspections and passing inspections have not changed, but the import can be carried out only after filing (about 5 working days), and the technical review will be carried out after the import, which greatly shortens the import market. time. The following is a comparison of the current filing materials and the materials required for administrative approval.

Bonded stocking VS collection direct mail VS overseas direct mail

Bonded stocking (customs supervision code: 1210)

"Online shopping bonded import" means that cross-border e-commerce companies use customs special supervision area policies and bonded warehousing policies to transport the goods they intend to sell into bonded warehouses (special customs supervision) for storage in advance. After consumers place orders online, The customs bonded department handles the customs clearance procedures, and the logistics company sub-packages them to the consumers. Compared with direct purchase imports, consumers can choose fewer categories, but due to the characteristics of centralized transportation and storage in China, the transportation cost is lower and the speed is faster. If you choose online shopping and bonded imports, you can enter the cross-border e-commerce platform or WeChat applet for sales. If you need to build your own cross-border e-commerce platform, you need a Chinese legal entity.

Consolidation Direct Mail (Customs Supervision Code: 9610)

The "direct purchase import" model means that qualified e-commerce platforms are connected to the customs. After domestic consumers make cross-border online purchases, electronic orders, payment vouchers, and electronic waybills (commonly known as "three orders in one") are transmitted to the customs in real time by the enterprise , Commodities enter the country through special customs supervision sites for cross-border e-commerce, and taxes are levied on personal postal items. Compared with the overseas direct mail model, the direct purchase import model synchronizes information with customs throughout the entire process, which is more sunny. Direct purchase imports are based on the brand's overseas warehouses, so consumers can choose more categories. However, direct-purchase imports are only shipped to China after consumers place an order, and they cannot be transported in large quantities, resulting in longer shipping times and higher costs. Brands who choose direct purchase and import can enter the cross-border e-commerce platform or WeChat applet for sales. If they need to build their own cross-border e-commerce platform, they need a Chinese legal entity.

Overseas direct mail (personal online shopping)

Beauty products can be sold to Chinese consumers through overseas direct mail. WeChat mini programs and overseas e-commerce websites can be selected as trading platforms. In principle, Chinese legal entities and domestic filing are not required . For overseas direct mail, if the amount of goods does not exceed the limit (Hong Kong, Macao and Taiwan 800 yuan, other countries 1,000 yuan, although it exceeds the prescribed limit, it is indeed personal use after customs review, customs clearance and customs tax can be collected according to personal items), according to the choice of logistics There are two taxation modes for different customs: express customs clearance (using international express companies such as DHL) will be levied 50% of the postal tax, and a single tax-free amount of 100 yuan; and postal customs clearance (selecting the EMS of the Universal Postal Union ) Using spot checks, if selected, the tax rate is equivalent to express customs clearance. If the amount of goods exceeds the limit, it will be levied in accordance with the general trade tax.

Q&A

Q: What is the difference between bonded stocking (1210) and online shopping bonded import A (1239)?

A: When the "1210" supervision method is used for import and export, it is limited to special customs supervision areas and bonded logistics centers (Type B) that have been approved to carry out cross-border trade e-commerce import and export pilots, that is, the existing cross-border e-commerce pilot cities. The original 37 pilot cities and regions will be expanded to the entire island of Hainan and 86 other cities (regions) in 2020, covering 31 provinces, autonomous regions, and municipalities directly under the Central Government. See "Ministry of Commerce and other six departments to further expand cross-border retail electricity supplier import scope of the pilot " . The "1239" model is applicable to other cities (non-pilot cities) that need to provide customs clearance forms for entry through special customs supervision areas and bonded logistics centers (Type B).

Q: Do beauty products imported into China through cross-border e-commerce retail need to pass animal experiments?

A: Entering China through the 1210 and 9610 modes does not require animal experiments and filing. However, according to the "List of Cross-border E-commerce Retail Import Commodities (2019 Edition)" , products listed in the "Import and Export Wildlife Species Commodity Catalogue" cannot pass The cross-border e-commerce model is sold to China.

Q: Do products sold through cross-border e-commerce retail require Chinese labels?

A: Beauty products imported through cross-border e-commerce retail do not have mandatory requirements for Chinese labels, but the following points need to be notified:

(1) The relevant products meet the requirements of the relevant quality, safety, sanitation, environmental protection, labeling and other standards or technical specifications of the place of origin, but may be different from my country's standards. Consumers bear the relevant risks themselves.

(2) Related products are directly purchased from abroad and may not have Chinese labels. Consumers can check the Chinese electronic labels of the products through the website.

Attached to the "Notice of the Six Departments on Improving the Supervision of Cross-border E-commerce Retail Imports"