Forget the misconception that animal tests are always needed if you want to export skin care to China. My discussion with Allie Rooke dove into the top clean beauty trends in China and explored strategies for successful market entry.

Beauty brands from all over the world want to know, how to win in China.

And why wouldn’t they? In 2020 China’s Beauty market was valued at USD 6.34 billion with an average growth rate of 12%.

Allie Rooke Biography

Allie Rooke - my discussion partner on top clean beauty trends in china

​​Allie has close to 20 years of experience in the beauty industry, driving local, regional and global strategies for Chanel, L’Oréal and Burberry Beauty.

Asia has been her home for most of the last 14 years having lived in Chengdu, Shanghai, Hong Kong, Jakarta and Singapore.

She now has a consultancy – Clean Beauty Asia which provides support to Indie Beauty brands wanting to enter and expand in Asia. Her key area of focus is cruelty free brands entering and expanding in China helping to ensure brands maintain their integrity and long-term strategic alignment by finding the right local approach and partners.

Regulatory Situation

In the past, clean beauty brands who wanted to sell in China were effectively limited to selling cross border when they wanted to enter the market due to the requirement for animal testing if you wanted to import and sell offline or on imported online channels.

From May 2021, there was a massive change in the regulatory makeup for for international brands coming into China. The biggest thing was that there was a route for brands with general use cosmetics (so not special use such as SPF or baby care)to enter the market without having to do any animal testing. There’s lots of things that can be categorised in special use though, and that’s a whole different set of ingredient metrics.

So, there’s now a route to market that doesn’t involve any animal testing. When it came out everyone was very excited and was like “fantastic, this is going to be a huge boom, it’s gonna be a massive change to the market”. The reality has been quite different. Whilst many cruelty free brands have managed to get into the market through this route it’s not easy.

There are lots of different barriers. For example, you need to have your GMP certificates certified by the government whereas in most markets around the world, governments don’t do that, and there’s no process in place. The regulatory organisations and also the local governments have slowly worked through this process so now, most major markets have the ability to support their brands to go enter into China in this way.

Of course COVID also slowed things down. We’re only really seeing brands coming through that now. And a lot of the brands that are through it already are the big brands, or at least owned by big groups, and the smaller brands are going through the process but there’s just quite a few hurdles to jump. There’s so much paperwork that you have to get in place though, that for a lot of very small brands it’s probably prohibitive to actually go that route and they are still effectively restricted to cross broder trading.

Regulatory implications for channel sales

Cross border ecommerce is still a good option and a lot of brands want to go through that as a first phase. They want to test the market. If you look at Tmall alone, cross border is still less than 10% of the total pie for Tmall so you can imagine that cross border as a piece of the total pie for the whole picture is almost insignificant. So whilst it’s an option, if you’re really serious about China, then you need to be serious about registration.

If you’re cross border, you’re only allowed to sell on pure cross border channels so whilst it’s a way to test, that’s why you’re so restricted because you’re only able to sell to those channels. Now those channels are eg Tmall global, or JD worldwide, these are specific channels for cross border.

Also you can’t sell in retail. There ARE ways to do pop ups and certain things in physical retail but essentially you can’t sell to regular physical retail. The definition of cross border is that the products have to be outside China. When the consumer places the order, the goods are outside China – that could be a bonded warehouse or it could be in Hong Kong or it could be anywhere in the world. So of course shipping times and costs also play a role.

That is still a very small part of the online pie, never mind the total market. So once you get registration you then have a whole world of domestic retail: domestic channels online, and also obviously, the offline piece. So offline is definitely not dead. For beauty, offline is still just under 50% of the market.

Clean beauty products in China
Photo: Florasis

You need to know which consumers buy in which retail channels

When you talk to consumers, you get different buying preferences. Some people are happy to buy everything online, but others want to go and discover products for themselves. A lot of consumers do go and try products but then they’ll buy online because they know they can get the best value online, however they still want to touch and feel and discover the products offline.

The Chinese consumer is much more willing to buy online without trying than a Western consumer though. The power of word of mouth, but also the power of the influencers is comparatively really very strong. Makeup is a good example where people are willing to just buy some lipsticks and try the colours rather than having to go into a store, whereas a western person would really want to try the product. At the same time there’s still the experiential aspect of buying offline and discovering new brands or clean beauty trends in China.

That’s why cross border is difficult because for so many of the new independent brands who start with cross border, they can’t be discovered organically through being in store so that’s a real conundrum of going into the China market.

Different Strategies for Clean Beauty Products in China

One of the disadvantages of entering any market purely in the online space is that you need to spend a lot of money to get visibility for your brand, even though it may initially appear a cheaper way to enter a market.

There are some brands that completely reformulate for China and immediately register for domestic trade because they want to build themselves up from that kind of physical retail opportunity. Whereas a lot of brands are not ready to reformulate for the market before they’ve even seen whether there’s any demand, so they go through the cross border route. Even though the cruelty free route now exists, there’re a lot of restrictions on ingredients. So if ingredients are not on the safe list then a product has to be reformulated in order to be registered.

Additionally there’s quite a lot of brands who, if they had a certain presence prior to 2021, they’d already done a certain amount of reformulation and so they were psychologically accustomed to the idea that they had to change things for China. They’re also hearing all the way that you need to localise for China, China is that one market where from day one, you really need to do a certain amount of localisation.

On the other hand though, China is all about speed so taking too long to redevelop your product can lose the opportunity.

Top Trends in Clean Beauty in China post Covid

Of course there was a big shift during COVID. As with everywhere else makeup dropped off a cliff because nobody was dressing up to go out to work. Skincare held strong and the market for skincare in China takes up at least 65% of the total share. Skincare even grew throughout covid (up until last year where everything dropped because of the lock downs), because people were at home and had more time for self care. This could also be seen in other markets as well.

People are still not spending like they were in 2019, they are still nervous about job stability. So everyone’s talking about “I want to I want to earn first and then spend” so there’s more of a mentality of being careful with spending.

So in terms of products & brands, the skincare & self care piece is still very much a trend. Looking at clean beauty trends in China, we’re seeing some streamlining of routines. So whilst people are not downgrading the products that they’re using (they’re still wanting to buy increasingly premium products), they want to streamline it so there are not so many steps in the routine. The Korean multi step routine is less on trend.

We’ve got the growth of niche fragrance although from a very small base. Fragrance is less than 10% of the market, but it’s really grown during covid and we’re seeing continued growth. So it’s really about the Gen Z, the younger consumers, they’re wanting to for the first time to show that individuality and a way of doing that is through niche fragrance. That’s a massive shift because fragrance used to be something purely for gifting in China. So that’s really changed.

There is definitely a trend in skincare for personalised skincare and personalised haircare: both of those things are nascent and small and no one’s really cracked it yet completely but they’re definitely up and coming.

Don’t ignore the clinical aspect

Chinese consumers are very data driven when selecting products be this food, beauty or other household goods. Their school system has trained them to read and absorb a lot of information – a fact which many brands underestimate.

[Chinese consumers] … are incredibly efficacy driven incredibly detailed and sophisticated in terms of what they want how the ingredients help with the specific concerns or effects they have

Allie Rooke

So even if your messaging talks about how natural your ingredients are, you need to prove the efficacy of the products, and that means showing the results of clinical trials or lab tests. It means using photographs of your production process and talking about aspects of the business that you might not be accustomed to showing customers.

Even if you don’t want to show certain documentation to the public, you have to be prepared to share a lot of product details with potential influencers that you want to work with as they need to be convinced about the products. They need you to be validated when they do their due diligence as they don’t want to risk their careers by working with the wrong brand.

Incidentally, this is also the same with your marketing assets. Even if you decide to enter via cross-border, don’t assume that it will be enough to translate your global marketing assets as China requires more marketing materials and content. So don’t underestimate the level of detail which will be required to win over Chinese consumers.

External Validation is Essential

If you don’t have testing from an international laboratory then chances are a KOL (influencer) will expect you to organise testing in a Chinese lab, which may use different test methods and standards, so it’s certainly better to organise in your home market.

The China market has struggled a lot with different kinds of scandals or with consumer trust on consumer products generally. So whilst in Europe it is quite normal that you self certify products from your own in-house laboratory (Which could be even better – it could be a higher standard laboratory than the state laboratories in your country, depending on what it is that you’re talking about), that’s not acceptable for a Chinese consumer. They want to have certification and testing from an external third party, and otherwise it’s not going to be taken on trust.

Build some level of awareness before entering the market

Prior to entering the Chinese market (either with a registration or via CBEC) then it’s worth doing a search on Red (xiaohongshu or XHS) or taobao to see if you can find any evidence of your brand. It’s not a disaster if you find your products being sold in the grey market – see it as a positive confirmation that there is already a certain level of demand for your brand. Chances are that the volumes being sold there won’t be large, but it is a clear indicator of interest.

You also need to build some awareness because in all reality, KOL’s are going to be a vital part of your future success and unless they can see some kind of validation about your potential as a brand they are not going to be willing to work with you. So how do you go about that?

You can start by working with influencers in your own markets, Chinese influencers in Europe. A warm up phase is increasingly important and actually, the length of the warm up phase is only getting longer. Unless you throw a huge amount of money at the market. Generally though, it’s better to do it more slowly over a longer period of time as otherwise, you end up paying fixed fees, and you end up having no traffic to your Tmall stores. You need to build up some buyers first.

Clean Beauty Trends in China: do consumers really understand what clean beauty stands for?

Up until a few years back, Korean skin care was the ultimate trending beauty product in China: highly scientific in the marketing and with a good reputation for keeping it’s promises. That’s fallen out of popularity now, and whilst the awareness of what constitutes clean beauty isn’t the same as in the US, UK or Australia we can certainly talk now about the rise of clean beauty in China.

The way it’s increasing is something we wouldn’t have predicted in the past & that’s from Chinese beauty brands. So there’s several Chinese beauty brands advocating clean beauty although it’s perhaps debatable whether or not they fit my definition of clean beauty or your definition. They’re bringing awareness to the market for sure though. These are brands such as Dewy Lab or even brands like Florasis, which are going in this direction.

Organic and vegan options in clean beauty are not the top priority

Even with the rise of clean beauty in China, this is seldom at the top of the priority list for consumers, so you need to amend your messaging accordingly. In fact this is a key point for any kind of marketing in China: revise your marketing messaging hierarchy according to the needs of Chinese consumers and not your usual brand hierarchy.

So if you normally would talk about the natural ingredients in clean beauty products as you main priority, for China in first place will be the functional efficacy. Remember that for Chinese consumers the term “natural” is almost synonymous with traditional Chinese medicine (TCM), a concept literally as old as the hills.

Also whilst awareness is high amongst certain target groups, such as pregnant ladies, that it’s better to use clean beauty products, this only has a short term impact on sales as the products are perceived to be less effective.

Which Marketing Channels should you focus on?

Pre-Covid, Tmall Global was the standard route to market for any cruelty free brands looking to gain traction in China. Many brands were unable to succeed here though as it was simply so expensive to drive the necessary traffic to say your Flagship Store. Tmall remains important, but today it’s simply one part of the mix together with especially the social commerce platforms.

Douyin was booming in 2023, with no end yet in sight! Sales were up a massive 70% year on year during the 618 festival (check out my China marketing calendar to learn more about that). To succeed you have to be using a combination of livestreams, your own store and also multibrand stores.

Xiaohongshu (Red or Little Red Book) is also an important channel. Very female focused as well as lifestyle driven, you can now also do livestreaming here too. KOLs such as Teresa Cheung or Dong Jie have been able to promote the first kind of lifestyle niche brands by focusing on the culture and history behind the names of products. This kind of quiet luxury approach is a far cry from the more aggressive sales style of Li Jiaqi and can be counted as one of the top trends in clean beauty in China. Both of these ladies have a really calm and elegant approach that educates rather than pushing products at viewers.

Of course Tmall and taobao (via distributors) also shouldn’t be forgotten as sales and marketing channels, and nor should you ignore the option of private selling on WeChat. Working with somebody who’s a distributor with their own store and their own following can be a great option, even if it’s maybe not quite as transparent to you where all of those sales are actually going and what’s driven them in the end. It’s exceedingly difficult to maintain full control and transparency when working in China as you will almost always have to cede some control to a distributor (even for big names this is the case). This means it’s imperative to be able to trust your partner.

Success with clean beauty products in China is not just about having the right range

Of course, you need to have the right products for the market, however that is just the basis! You also need to ensure that you have the right strategy for the category – where do you plan to sell and how? What is your marketing strategy? On top of that it’s essential to think carefully and look at the data about consumer targeting. Who will you partner with? Can you REALLY trust them or do you need to spend more time working on that relationship? Finally, you need a little luck with your timing…

Full Discussion

You can find the full discussion with Allie on my YouTube channel – it would be a great help if you would like, subscribe and comment on the video – thanks!!

If you’d like to get in touch with Allie, you can contact her here:

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