A practical side-by-side guide for foreign SME owners — three regulatory pathways compared.
There is no single answer to "what do I need to do to sell in China?" — because there is no single way to enter. You can:
Regulatory context (2024–2026): China's Foreign Investment Law (2020) established a "pre-establishment national treatment + Negative List" framework. The 2024 Company Law tightened capital rules. The 2026 VAT Law formalised long-standing VAT rules. These affect Route C primarily; Routes A and B are largely insulated from corporate law changes.
| Your situation | Route A: CBEC | Route B: General Trade + IOR | Route C: WFOE |
|---|---|---|---|
| Product type | Packaged consumer goods only — cosmetics, supplements, food, baby products, fashion, small electronics | Any product — food, industrial goods, medical devices, bulk materials, chemicals | Any product — same as Route B, plus services, software, consulting |
| Sales channel | Online only (Tmall Global, JD Worldwide, etc.) | Online + offline retail + B2B + wholesale | Any channel |
| Chinese entity? | No | No — use a licensed IOR | Yes — WFOE |
| Onshore staff? | No | Maybe | Yes |
| Pre-approval | Partial exemptions | Full registration/certification | Full registration/certification |
| Duty / VAT | Duty 0%, VAT at 70% | Standard duty + full VAT | Standard duty + full VAT (input credit) |
| Best for | Testing, low volume, B2C | Established products, B2B, retail | Long-term, brand building, full control |
| Complexity | Low | Medium | High |
The Chinese government maintains a Positive List of ~1,400+ HS code categories. If your product is not on this list, CBEC is not available.
Your overseas production facility must be registered with GACC. Since June 1, 2026 (Decree 280), overseas food producers apply directly via the CIFER system. Health foods require endorsement from your national competent authority. Registration is valid for 5 years and free.
Overseas cosmetics manufacturers must appoint a Chinese responsible person for NMPA registration or filing.
Your product must bear a Chinese label (or a sticker applied at the bonded warehouse). See Labeling & Standards for details.
Limitations of CBEC: Per-order and annual transaction limits apply. Products cannot enter offline retail. You cannot collect Chinese consumer data directly.
Your IOR must hold a business license with import/export rights. Conduct due diligence — a poor IOR choice is one of the most common entry mistakes.
Even though the IOR imports on your behalf, the overseas producer must be registered:
See the Cross-Route Essentials section for labeling, trademark, and advertising requirements that apply to all routes.
Review the current Negative List to confirm your business is not restricted. Manufacturing is fully open since November 2024.
| Step | Timeline |
|---|---|
| 1. Name reservation with AMR | 1–3 days |
| 2. Document notarisation (Hague Convention) | 2–4 weeks |
| 3. Business license from AMR | 5–10 working days |
| 4. Company chops (official, financial, legal rep, invoice) | 1–3 days |
| 5. SAFE registration for capital injection | 1 week |
| 6. Bank accounts (RMB + foreign currency) | 1–2 weeks |
| 7. Tax registration + fapiao issuance | Within 30 days |
| 8. Customs registration (if importing) | Alongside tax reg. |
| 9. Foreign investment report to MOFCOM | After license |
Plus additional obligations:
Tax incentives: HNTE (15% CIT), Small Low-Profit Enterprise (~5%), R&D super deduction (200%), reinvestment credit.
China operates a "first-to-file" system. Register with CNIPA before entering the market.
Food & beverage — GB 7718-2025 (effective March 16, 2027): Allergen labeling now mandatory. "No additive" claims banned for substances that cannot legally be added.
Nutrition — GB 28050-2025: New mandatory items: saturated fat, sugar. Warning label required.
Cosmetics: INCI ingredients in Chinese; NMPA number on label.
Language Law (Jan 1, 2026): Chinese must be dominant; homophone puns prohibited.
| Category | Approval | Route A | B/C |
|---|---|---|---|
| Food (general) | GACC producer registration | Yes | Yes |
| Health food | SAMR + GACC | Partial | Full |
| Infant formula | SAMR formula registration | No | Yes |
| Cosmetics (ordinary) | NMPA filing | Yes | Yes |
| Cosmetics (special) | NMPA registration | Partial | Yes |
| Electronics (CCC scope) | CCC certification | Case-by-case | Yes |
| Medical devices | NMPA registration | No | Yes |
| Pet food | GACC + MARA | Partial | Yes |
| Restriction | Penalty |
|---|---|
| Absolute terms ("best," "#1") | Up to CNY 200,000/violation |
| False advertising | Up to CNY 2M or 10% of revenue |
| Unverified statistics/surveys | Treated as false advertising |
| Health/functional claims without approval | False advertising penalties |
China's definition of commercial bribery is broad. Business gifts should not exceed ~CNY 200 per item. The 2025 revision of the Anti-Unfair Competition Law (effective Oct 15, 2025) tightened rules further.
| Compliance item | Route A: CBEC | Route B: IOR | Route C: WFOE |
|---|---|---|---|
| CBEC Positive List check | ✓ | — | — |
| Negative List check | — | — | ✓ |
| Select CBEC platform | ✓ | — | — |
| Select/vet Importer of Record | — | ✓ | — |
| Incorporate WFOE + capital injection | — | — | ✓ |
| GACC overseas producer registration | If food | ✓ | ✓ |
| NMPA registration (cosmetics) | ✓ | ✓ | ✓ |
| CCC certification | Check | ✓ | ✓ |
| Chinese label (GB standards) | ✓ | ✓ | ✓ |
| Trademark registration (CNIPA) | ✓ | ✓ | ✓ |
| Advertising review | ✓ | ✓ | ✓ |
| Anti-bribery policy | Advised | ✓ | ✓ |
| Tax registration (VAT + CIT) | — | — | ✓ |
| SAFE registration | — | — | ✓ |
| Social insurance + housing fund | — | — | ✓ |
| Labor contracts + HR | — | — | ✓ |
| PIPL compliance | Platform handles | If collecting | ✓ |
| ICP License (if own website) | — | If applicable | If applicable |
| MLPS/deng bao | — | If applicable | ✓ |
| Environmental EIA (if manufacturing) | — | — | If applicable |
Every brand's journey into China is unique. Tell us about your business, and we'll help you build a strategy tailored to your specific product, budget, and goals.
Get a ProposalChina Foreign Investment Law (2020) & Negative List (2024 edition)
Company Law of the PRC (2024 revision, effective July 1, 2024)
VAT Law of the PRC (2026, effective January 1, 2026)
GACC Decree 248 & 280 — Overseas food producer registration
NMPA — Cosmetic Supervision and Administration Regulation
SAMR — Food safety, advertising, and anti-bribery regulations