Can gel nail products be imported and sold?
The answer is yes! Gel nail products are not classified as cosmetics, so they can be imported from China and sold as general merchandise.
Importing them as general merchandise eliminates the need for the complex Cosmetics Manufacturing and Sales Notification, making the import process much simpler.
To import and sell them as miscellaneous goods, the following requirements must be met:
1: The product must not be a base gel applied directly to the nails.
2: The product must be a gel nail product applied as the second layer or later, not directly onto the nails.
3: It must be clearly stated that the product is not applied directly to the nails.
4: For products applied to the second layer or later of human nails
both of the following labels (a and b) must be clearly displayed in a location easily visible to consumers:
a. A statement indicating that the product “cannot be applied directly to the nails”
b. A label stating “General merchandise” or “Miscellaneous goods”
5: For products intended exclusively for artificial nails
Be sure to display both of the following (a) and (b) in a location easily visible to consumers.
a. A statement indicating that the product “cannot be used on human nails”
b. A label stating "For artificial nails only" or "For nail tips only"
6: Other Precautions
We have compiled examples of these labels.
Additionally, include a label stating "Do not apply directly to natural nails" and a label indicating "General merchandise" or "Miscellaneous goods" in a location easily visible to consumers.
Fun Fact 1: Even natural nails become artificial nails once the base gel is cured.
Color gels and top gels applied over them can be imported and sold as general merchandise (miscellaneous goods).
Trivia 2: Even for gel nails classified as general merchandise, manufacturers (or sellers) are required to ensure safety.
Tip 3: It is acceptable to have both cosmetics and general merchandise within the same brand, but measures must be taken to prevent consumer confusion.
Visibility must be enhanced, such as by differentiating them through container or label design.
When switching products originally sold as cosmetics to general merchandise, it is necessary to review all product packaging and product pages.
★ When actually importing these products, you may be asked by the shipping carrier or customs whether they fall under the Pharmaceutical Affairs Law. In such cases, if you provide a factual explanation that the products do not fall under the Pharmaceutical Affairs Law, importation will be permitted.
★ Regarding labeling and packaging, we recommend consulting with the Pharmaceutical Affairs Division of your prefectural government and presenting specific examples.
When importing gel nail products as general merchandise, please be sure to contact HubBuyer, a China-based import agency specializing in sourcing from China. Our experienced staff will be happy to assist you.
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