What is GACC Order 284?
GACC is the General Administration of Customs of China. It is the agency that decides what happens to a shipment when it arrives in the country: whether it is inspected, where, and what paperwork has to accompany it.
On 6 May 2026 it issued Order No. 284 — six chapters and thirty-seven articles setting out how imported and exported cosmetics are inspected and supervised. Five days later, on 11 May, it followed with Announcement No. 61, the practical companion document covering how you declare a shipment, what you have to record about it, and how pre-export inspection works.
Both take effect on 1 December 2026. That is just under three months from now.
The rules being replaced are old. The instrument was promulgated in 2011, took effect in February 2012, and was amended three times during 2018. So this is the first proper rewrite of the customs rulebook for cosmetics since it was written.
Korean exporters got a clear summary of it on 31 August, when the Korea Cosmetic Industry Institute published the China and Japan edition of its Global Cosmetic Focus report. China matters here: it is Korea's second-largest cosmetics export destination, worth USD 120m in the first twenty-five days of August alone.
What is a cosmetics filing, and why does a drug regulator handle it?
One piece of background makes the rest of this readable.
In China, cosmetics are regulated by the country's drug regulator, not by a separate beauty authority. Before a cosmetic can be sold there, it has to be registered or filed with that regulator — a formal record stating what the product is, what is in it, what it claims to do, and who makes it. Ordinary products are "filed"; products making special claims go through fuller "registration". Either way, the result is a number, and that number is what customs looks up.
Crucially, the filing is usually held by a Chinese entity, not by the foreign brand. In a typical arrangement the Chinese importer — the "domestic consignee", meaning the company that legally receives the goods inside China — is the one whose name is on the paperwork.
So there are two separate documents describing the same jar: the filing sitting in a Chinese database, and the physical product sitting on a pallet in Korea. Everything below is about what happens when those two stop matching.
What actually gets easier under Order 284?
Quite a lot, and the facilitation is genuine.
The filing obligations that used to apply to the Chinese consignee and to the overseas manufacturing company are gone. Announcement No. 61 expressly repeals the 2016 provisions that required domestic consignees of imported cosmetics to be filed.
Inspection moves from the port of entry to the destination the consignee declares — in plain terms, from the dockside to wherever the importer says the goods are going. Customs keeps the power to designate somewhere else if it wants to, so this is not absolute, but it is the normal case now.
The special handling that used to apply the first time a given cosmetic was imported has been removed. Certain samples are exempt from inspection. Semi-finished cosmetics move to a lighter regime and are exempt from registration, filing and label verification at import.
"Semi-finished" is worth defining, because it is doing real work here. It means the product is finished in every respect except the last step — filling it into its final container, or repacking it. Bulk cream in a drum, in other words, on its way to a Chinese filling line.
And customs now checks registration data by automatic electronic comparison against the drug regulator's systems, rather than by a person reading documents.
For an exporter who is already well organised, that adds up to a straightforwardly good week. Goods spend less time sitting at a port. Inland distribution is easier to plan. Shipping product in bulk to be filled in China gets cheaper.
What conditions are attached to the new exemptions?
Here is where the reading gets less cheerful, and where most summaries stop.
The sample exemption is not a wave-through. To use it, the declarant supplies a statement of what the samples are for and how they will be disposed of, plus an undertaking that they will not be sold, and keeps the quantity within a reasonable range. Then, depending on what kind of sample it is, they produce either a testing institution's certificate, or a research and development plan with the commissioning agreements behind it, or a promotion plan naming the location, the method, the audience and the disposal.
That is not nothing. It is a documentation exercise in place of an inspection.
The semi-finished exemption works the same way. It covers only product that is complete except for final filling or repacking — and the declaration has to name the filling enterprise, its address and its production licence number.
So the pattern repeats: verification at the border is traded for disclosure of your supply chain. You no longer have to be checked. You do have to say who your partners are, on the record.
And the record-keeping requirements were tightened outright. Records must be truthful, complete and traceable. They have to be kept for at least a year past the product's shelf-life expiry — two years where the shelf life is under a year. Announcement No. 61 specifies eighteen mandatory fields, batch number and manufacturer name among them.
Why does moving inspection from the port to the warehouse matter?
Because of when you find out you were wrong, and where your goods are when you do.
A port inspection is a checkpoint. Someone else opens the box, compares it against the filing, and tells you the answer on a known date, before the goods have gone anywhere. It is slow and it costs money in storage — but it is also, if you are honest about it, a free proofreading service. Somebody outside your company was checking that your paperwork and your product described the same thing.
Destination inspection removes the checkpoint without removing the requirement. If something does not line up, the container is already inland, already in a warehouse, possibly already being picked for orders. The problem is the same problem. The cost of discovering it is much higher.
Automatic electronic comparison sharpens the point. A person reading a document can notice that something looks odd and ask a question. A system comparing a declaration against a database produces a result. It does not wonder.
Why does this hit Korean exporters harder than most?
This next part is my reading rather than something any of these documents says, and I want to be clear about that.
Most Korean cosmetics brands do not own factories. They design and market the product and have it made by a contract manufacturer — an ODM, in the industry's shorthand, a company that both develops and manufactures on the brand's behalf. That arrangement is why Korea can launch new products so quickly, and it is the backbone of the export business.
The consequence is that in a typical China shipment, three different organisations each hold one piece of the same truth.
The Chinese importer holds the filing. The Korean brand owner holds the label artwork and the marketing claim. The contract manufacturer holds the formula revision actually used, the ingredient list as actually produced, and the batch record.
Nobody holds all three. Until now, nobody had to — because a border check reconciled them for free, externally, on a fixed date, before the goods reached a customer.
The honest counter-argument is that Order 284 is trying to fix precisely this. Requiring the importer to record batch number and manufacturer name, and to name the filling enterprise and its licence number, drags manufacturing-level detail into the importer's file whether the supply chain volunteers it or not.
That is exactly the point. The data those fields ask for sits in Korea. The party being made to attest to it does not. Somebody has to send it, and the deadline for building that habit is 1 December.
Does this apply to cross-border e-commerce sales into China?
No, and this is an important limit on everything above.
Cross-border e-commerce — where a Chinese consumer buys directly from an overseas seller and the parcel ships to them individually, rather than the goods being imported in bulk and sold domestically — sits outside these Measures altogether. A meaningful share of Korea-to-China cosmetics volume moves that way and is unaffected by Order 284.
If your China business is entirely direct-to-consumer through those channels, this is background reading. If any of it moves in containers to a Chinese importer, it is not.
What is the triheptanoin restriction in Japan, and why is it the same story?
The same institute report carries a Japanese case that is the identical move seen from the other direction.
On 23 March 2026, a medicine using triheptanoin as an active ingredient was approved in Japan. Under Japanese rules that has a knock-on effect: once a substance is an active pharmaceutical ingredient, putting it in a cosmetic is restricted in principle.
Triheptanoin is not an exotic ingredient. Korean trade coverage describes it as a widely used emollient — the class of ingredient that makes a cream feel soft and smooth on the skin — found in creams, lotions and lip products, and present in many products already on sale.
On 20 April, Japan's Ministry of Health, Labour and Welfare issued an administrative communication permitting continued sale where the concentration is at or below the level in products already being manufactured and sold at that date, with safety confirmed under the company's own responsibility. Raise the concentration, or launch something new, and it does not cover you.
Notice what does not happen. No shipment is stopped. No inspector fails you. Nothing arrives at your door at all.
The exposure sits inside a document the exporter already holds. Finding it means reading the full ingredient list of every product currently going to Japan and looking for one word. Which is, in substance, exactly what the institute told Korean exporters to do.
[image] Image 3 — posterised painterly portrait, 1.91:1, portrait with object Editorial illustration, posterised painterly style, flat gouache background, visible brushwork. One invented man in his fifties, fully rendered characterful face, seated in three-quarter view holding a thick unmarked binder open on his lap, looking down at it with concentration. Background is a bold flat repeating pattern of long horizontal rules suggesting ingredient lines, in staggered blocks. Limited palette: purple, mustard, cream, brick red, deep blue. No text, letterforms, numerals or logos anywhere. The person is invented and must not resemble any real person. Replace this whole box with the image.
What should a cosmetics exporter do before 1 December 2026?
The institute's advice reflects the shape of the problem, and it has two halves rather than one.
Tidy the registration information, so that what the Chinese filing says matches what is actually in the box. And tidy the label-management system, ahead of an electronic-label pilot beginning in Shanghai's Pudong New Area. Two systems, not one — and most companies have been treating them as a single annual chore.
There is a version of January in which a consignment sits inland against a record that does not match what is in the box, and the exporter concludes that China moved the goalposts. China did not. It published them on 6 May, explained them on 11 May, and a Korean institute put them in front of the industry on 31 August.
What is the general lesson here?
Facilitation removes checks. Some of those checks were quietly doing reconciliation work that nobody had budgeted for, because nobody was being invoiced for it.
When the checks go, the work does not. It lands on whoever inside the company is supposed to know what is actually in the product, what the label actually says, and what the filing actually claims.
In a great many cosmetics exporters, that person does not exist yet.
Three months is enough time to hire them.
