Two documents that answer different questions
China issues two separate documents, and both appear on a compliant label.
The first is the cosmetics production licence. It is held by the factory, it is issued by the drug regulatory authority of the province where the plant is located, and without it a company may not manufacture cosmetics in China at all. It runs on a five-year cycle.
The second is the product number, filed or registered for a specific product under a specific brand owner. This is the number retail buyers in China mean when they talk about a registration number, and it belongs to the product rather than to the plant.
The distinction matters commercially. A factory can hold a valid licence and still not be permitted to make your product category. A product can carry a valid filing number and still be made in a plant you would not choose. Checking one tells you nothing about the other.
What the production licence actually carries
The licence is not a single line. It records the licence number, the name of the legal entity, the registered address, the production address, the unified social credit code, the legal representative, the permitted production items, the validity period, the issuing authority and the date of issue.
The licence number is not random either: it encodes the province that issued it, the four-digit year of issue and a serial number. A number that does not correspond to the province you are told the plant sits in is worth a direct question.
Since 2017 this licence has replaced the earlier industrial production licence and the separate factory hygiene licence, so documents carrying those older names may still appear in a supplier archive. They are historic, not current.
One structural point is worth knowing before you read the document: a single production site may hold only one licence, and a licence cannot be rented, lent or transferred. If the licence is in the name of a company you are not contracting with, that is a question about who is actually manufacturing your order.
The scope line is where most checks stop too early
The licence lists permitted production items, organised by production process, product form and use. The categories cover a general liquid unit, a cream and lotion unit, a powder unit, an aerosol and organic solvent unit, a wax-based unit, a soap-based unit, and an open unit for other products. Where a plant is equipped to produce skincare for children or for the eye area, that capability is separately marked on the licence.
Read this line against your own product rather than accepting a summary of it. A licence covering liquids and emulsions does not make a plant licensed for aerosols, because the equipment, the ventilation and the safety controls involved are different. Ask which units appear on the licence, and confirm that the unit matching your product type is among them.
- Which production items are listed on the licence?
- Which of them covers my product type?
- If my formula needs a unit that is not listed, how would that work be handled?
The product number: filing or registration
Chinese rules divide cosmetics into two tracks. Products treated as lower risk are filed with the regulator; this covers ordinary cosmetics, which includes most skin care, hair care, cleansing and colour products. Products in the higher-risk categories are registered instead, under a stricter review. Hair dyes, permanent wave products, whitening and freckle-removing products, sunscreens, anti-hair-loss products and anything claiming a new efficacy fall into the second group.
The number reflects both the track and the origin of the product. A domestic ordinary cosmetic carries a number built from the province designation, the four-digit year and a serial number. A domestic product in a higher-risk category carries a national designation instead of a provincial one. Imported products carry their own forms again.
For sourcing, the question that matters is who holds the number. The filing or registration belongs to the brand owner rather than to the factory, unless the factory is also the brand owner. Ask who will hold the number for your brand, and in whose name it will be filed.
Who carries the responsibility
The rules are explicit about contract manufacturing. A brand owner may manufacture its own products or entrust the work to another company. Where production is entrusted, it must go to a factory holding the corresponding production licence, and the brand owner remains responsible for the quality and safety of the product and is required to supervise the manufacturing process. The factory is responsible for its own production activities and must accept that supervision.
This is why a supplier cannot simply absorb your regulatory position. When a supplier says compliance will be handled, ask which obligations are being taken on and which remain with you. The answer is usually a split, and knowing where the line falls prevents an unpleasant discovery after the launch.
Record keeping has its own clock as well. Purchase-inspection records and sales records must be kept for at least one year after the product expiry date, and for at least two years where the shelf life is shorter than a year. A factory that cannot describe this retention in plain terms is not running the system the licence assumes.
What the licence does not tell you
- It does not make a product compliant in your market — destination labelling, restricted ingredients and import paperwork are separate questions
- It does not cover a formula; the formula sits in the product filing or registration
- It does not prove the plant operates today the way it did at the last review
- It does not confirm the plant is equipped for your particular process, which is why the scope line and a look at the line itself still matter
How to verify both, and what to ask
Neither document has to be taken on trust. Both are issued by regulators that maintain public databases, and a buyer can look up a licence or a product number without asking the supplier for permission. The practical habit is to ask for the licence as a document rather than as a number, so that the entity name, the production address and the permitted units are visible together on one page.
These questions tell you whether the paperwork is being presented or actually explained:
- What is the licence number, and which province issued it?
- Which production items are listed, and which one covers my product type?
- Does the production address on the licence match the site that will make my order?
- Is the licence held by the company I am contracting with, or by a related entity?
- Who will hold the filing or registration number for my brand, and in whose name?
- Which records can I see for a completed batch, with commercial details removed?
The licence and the product number answer two different questions, and a supplier who can explain which is which — and show you both documents — is a supplier whose paperwork can be relied on. Ask for the documents, not the assurance.
