Entry routes into China are usually described as four: general trade, cross-border e-commerce, a local distributor and a local entity. General trade usually runs through a local distributor, so the table compares three tracks. It sets out what each route requires and restricts, based on official documents, using cosmetics as the example. Other product categories have their own rules.
At a glance
| Item | Cross-border e-commerce retail import | General trade + local distributor | Local entity |
|---|---|---|---|
| Who sells | An overseas company sells directly to Chinese consumers | A Chinese importer or distributor buys and resells | Your Chinese subsidiary imports and sells |
| Product registration or filing (cosmetics, NMPA) | First-import licence, registration and filing requirements do not apply | Required | Required |
| Chinese label | May be absent (Chinese e-label shown online) | Required | Required |
| Who can buy | Personal use only; resale prohibited | No restriction (offline and online) | No restriction |
| Products | Items on the Cross-Border E-commerce Retail Import Product List | Importable goods | Importable goods |
| Tax | Within limits: 0% tariff; import VAT and consumption tax at 70% of the statutory amount | Normal goods rates | Normal goods rates |
| Party needed in China | A company registered in China, appointed to register with and declare to customs | The importer or distributor | The subsidiary itself |
1. Cross-border e-commerce retail import (跨境电商零售进口)
- Definition: Chinese consumers buy overseas goods on a cross-border platform, and the goods enter via bonded import (customs code 1210) or direct-purchase import (9610) (Shangcaifa [2018] No. 486, six ministries led by MOFCOM).
- Registration: goods are supervised as personal-use articles; first-import licence, registration and filing requirements do not apply, except for goods banned from import or under emergency measures for a major quality or safety risk.
- Seller duties: the overseas seller appoints one company registered in China to register with customs and make declarations; that company bears joint civil liability. The seller is responsible for quality and safety, returns, recalls and a risk notice to consumers.
- No resale: consumers may not resell what they buy. “Buy online, pick up in store” for bonded goods is in principle not allowed outside special customs supervision zones.
- Limits and tax: RMB 5,000 per transaction and RMB 26,000 per person per year. Within the limits the tariff is 0% and import VAT and consumption tax are charged at 70% of the statutory amount. A single-item order above RMB 5,000 but within the annual limit can still enter this way, taxed in full at goods rates (Caiguanshui [2018] No. 49).
- Fits when: you want to test demand before NMPA registration, or sell through cross-border channels such as Tmall Global or JD Worldwide.
2. General trade + local distributor
- Registration: cosmetics must be registered (special cosmetics) or filed (general cosmetics) with NMPA before import and sale. Imported cosmetics need a domestic responsible person (境内责任人).
- Animal testing: toxicology test reports can be waived when conditions are met. See the animal testing exemption table.
- Check the distributor: before signing, check company registration, lawsuits and enforcement, customs credit and trademark filings. China partner check
- Fits when: you want offline stores and domestic channels such as Douyin or Tmall (domestic).
3. Local entity
- Principle: China’s Foreign Investment Law applies pre-establishment national treatment plus a negative list. Sectors not on the negative list (Special Administrative Measures for Foreign Investment Access) are open on the same terms as domestic companies.
- Registration: products imported by the entity still need the same NMPA registration or filing as general trade. The entity can act as the domestic responsible person.
- Fits when: you want control of distribution, pricing and local marketing. Setup and running costs, tax and employment obligations follow.
How to choose
- Is the product on the cross-border retail import list? If not, only general trade is possible.
- Do you need offline stores or domestic e-commerce channels? Then you need general trade with registration or filing.
- Do you want to test demand before registration? Cross-border is faster.
- Do you need direct control of distribution? Consider a local entity; otherwise start with general trade through a vetted distributor.
Original documents
- MOFCOM and five other agencies, Notice on Improving Supervision of Cross-Border E-commerce Retail Imports (Shangcaifa [2018] No. 486)
- MOF, GACC and STA, Notice on Improving Tax Policy for Cross-Border E-commerce Retail Imports (Caiguanshui [2018] No. 49)
- Summary of NMPA Notice No. 32 (2021) and No. 70 (2026)
As of 4 November 2026. Limits, tax rates and the product list can change; confirm current rules with customs and your agent before contracting or clearing goods. This page is not legal or tax advice. Related: China platform setup guide · platform rule changes