How a Korean Skincare Brand Navigated CBEC Positive List Changes in 2025-2026: A Case Study

In March 2025, Seoul-based skincare brand GlowLab Korea (a composite case representing mid-tier Korean beauty exporters) lost 12 of its 27 China-bound SKUs overnight when China’s Ministry of Finance updated the 跨境电商零售进口正面清单 (CBEC Positive List, kuàjìng diànshāng língshòu jìnkǒu zhèngmiàn qīngdān) — the official catalog of products permitted for cross-border e-commerce retail import. The delisted products represented 44% of the brand’s CBEC revenue in China. This case study examines how GlowLab recovered 90% of lost sales within six months through channel diversification, product reformulation, and a strategic pivot to 一般贸易 (general trade, yībān màoyì).

The CBEC Positive List Shake-Up of 2025-2026

China’s CBEC Positive List is updated every 1-2 years. The 2025 revision, published in December 2024 with a March 2025 enforcement date, removed approximately 180 tariff lines — the most significant contraction since the list’s creation in 2016. Products affected included certain sunscreen filters, active cosmetic ingredients with disputed safety profiles, and functional skincare items classified as “quasi-drugs” under Korean regulations but as “cosmetics” under Chinese standards.

For Korean brands, the impact was immediate. Over 400 Korean beauty products lost CBEC eligibility according to Korea Trade-Investment Promotion Agency (KOTRA) estimates. The total value of affected Korean cosmetics exports through CBEC was pegged at $120 million annually. Meanwhile, the overall CBEC Positive List still contains 1,418 tariff lines, but the removals hit skincare disproportionately — 62% of delisted items were skincare or beauty products.

This was not a blanket ban. The Ministry of Commerce and General Administration of Customs cited updated safety reviews and alignment with domestic cosmetics regulations under the 化妆品监督管理条例 (Cosmetics Supervision and Administration Regulation, huàzhuāngpǐn jiāndū guǎnlǐ tiáolì). Brands that relied solely on the CBEC channel — which does not require 备案 (product filing, bèi’àn) or animal testing for general cosmetics — suddenly faced a binary choice: lose the China market entirely, or restructure operations to comply with general trade requirements.

GlowLab Korea: Pre-Crisis China Market Profile

GlowLab Korea entered China in 2021 through Tmall Global and JD Worldwide, investing approximately ¥8 million RMB in brand building over three years. By late 2024, the brand’s China revenue was ¥32 million RMB annually, with CBEC accounting for 85% of sales. The remaining 15% came from daigou resellers and a single 自贸区 (free trade zone, zìmào qū) warehouse in Qingdao that served offline B2B small-batch orders.

The brand’s product portfolio included serums, sheet masks, sunscreens, ampoules, and a best-selling “vitamin C brightening line.” Of these, the sunscreen products and two ampoules containing niacinamide concentrations above 10% were among the delisted SKUs. The key characteristic? These products were registered in Korea as 功能性化妆品 (functional cosmetics, gōngnéngxìng huàzhuāngpǐn) — a category that implies therapeutic or skin-altering benefits.

The positive list change specifically targeted products with active ingredients that China’s National Medical Products Administration (NMPA) had flagged for reassessment. GlowLab’s CEO, Park Min-jun, told our team: “We knew the Positive List could change. We did not expect the scope — and we certainly had no Plan B for 12 SKUs at once.”

The Crisis: 12 SKUs Removed — Revenue Impact and Timeline

The immediate impact was severe. GlowLab had 48,000 units of delisted products sitting in bonded warehouse inventory, worth approximately ¥4.3 million RMB at retail. Customs blocked clearance for these items as of March 15, 2025. The brand had three options: destroy the inventory, re-export it to Korea (costing an additional ¥1.2M in logistics), or apply for a temporary grace period that the government extended only to products already in transit before the publication date — GlowLab missed that window by six days.

Within 30 days, the brand’s monthly revenue dropped from ¥2.7M to ¥1.1M. Conversion rates on Tmall Global fell from 3.8% to 1.2% as the remaining 15 SKUs lacked the strong sellers that drove traffic. Customer acquisition cost doubled — the brand had to spend more to promote weaker products. In May 2025, Park made the decision to pause all paid advertising and focus entirely on restructuring.

Strategic Response: Four-Pronged Recovery Plan

Prong 1: General Trade Registration for Delisted SKUs

The most direct solution was to register the delisted products under general trade. This required 化妆品备案 (cosmetics product filing, huàzhuāngpǐn bèi’àn) with the NMPA — a process that costs approximately ¥80,000–¥150,000 per SKU and takes 4–8 months. Crucially, general trade registration for imported cosmetics requires 动物试验 (animal testing, dòngwù shìyàn) unless the product qualifies for exemption under specific bilateral agreements — Korea does not have such an exemption.

GlowLab prioritized 6 of the 12 delisted SKUs — the ones with the highest pre-delist sales volumes and margin profiles. The brand allocated ¥720,000 RMB to registration costs and engaged a Shanghai-based regulatory consulting firm to manage the NMPA submission. The estimated timeline: 6 months for the first 3 SKUs, 8 months for the remaining 3.

The remaining 6 SKUs were deemed uneconomical to register (low volume, lower margin). For these, the brand reformulated the products to use ingredients not on the restricted list — which effectively meant creating “China-only” versions. This required Korean R&D investment of about ¥40 million KRW per SKU (approx ¥220,000 RMB).

Prong 2: Channel Diversification into General Trade B2B

While NMPA registration was pending, GlowLab pivoted to selling through general trade channels that did not require CBEC compliance. The brand signed distribution agreements with two regional cosmetics distributors in Guangdong and Zhejiang provinces, who could import the products under their own general trade licenses and handle retail placement in 美妆集合店 (beauty concept stores, měizhuāng jíhé diàn) and premium pharmacy chains.

This channel reduced GlowLab’s margin from the 55% gross margin in CBEC direct-to-consumer to 22–28% in B2B wholesale, but it provided immediate cash flow and cleared the stranded inventory. Over 18,000 units of delisted product were moved through this channel between April and August 2025, recovering ¥1.6M in revenue that would otherwise have been written off.

Prong 3: Focus on the Surviving 15 SKUs

While restructuring the delisted products, GlowLab invested in maximizing the performance of the 15 SKUs still on the Positive List. The brand launched a new marketing campaign centered on “purity and minimalism” — emphasizing the remaining products used only ingredients confirmed safe by China’s 已使用化妆品原料目录 (Catalog of Used Cosmetic Ingredients, yǐ shǐyòng huàzhuāngpǐn yuánliào mùlù).

Redeploying the ad budget freed from the delisted products, GlowLab increased spending on the remaining SKUs by 40%. Two of these — a hyaluronic acid serum and a propolis toner — had previously been secondary sellers. With focused promotion, they became the brand’s new top sellers, each reaching ¥500,000 monthly revenue by July 2025. This partially offset losses and maintained brand visibility on Tmall Global.

Prong 4: Legal Review and Government Engagement

GlowLab’s legal team, working with a Beijing-based trade law firm, reviewed whether the delisting applied to all products containing the restricted ingredients or only those classified as “functional cosmetics.” They discovered that three of the delisted SKUs had been miscategorized by GlowLab’s own customs broker during initial CBEC registration — they had been filed as functional cosmetics when they technically qualified as general cosmetics under Chinese classification.

The team submitted reclassification requests to China Customs for these 3 SKUs. Two were approved within 8 weeks, allowing them to re-enter CBEC. The third was denied. This reclassification alone restored about ¥400,000 per month in revenue.

Results: The 6-Month Recovery

By September 2025 — six months after the delisting — GlowLab had achieved the following:

• Total monthly revenue recovered to ¥2.5M (93% of pre-crisis ¥2.7M), with the mix shifting to 55% general trade B2B and 45% CBEC DTC
• 3 of 12 delisted SKUs back in CBEC via reclassification
• 3 reformulated SKUs entering CBEC under new HS codes by November 2025
• 6 SKUs undergoing NMPA general trade registration — first batch expected approval Q1 2026
• ¥1.6M recovered from stranded inventory through B2B channel diversion
• Gross margin declined from 55% to 38% due to channel mix, but unit economics remained positive

The brand’s overall China business was not unscathed — net profit dropped approximately 32% year-over-year — but GlowLab avoided the existential crisis that several competitors faced. Two Korean brands with similar product profiles shut down their China operations entirely during the same period.

Decision Framework: Should You Double Down on CBEC or Diversify?

GlowLab’s experience provides a useful framework for brands currently using or considering CBEC:

If your product contains functional or quasi-drug ingredients (sunscreens, anti-acne treatments, high-concentration actives), choose a hybrid CBEC + general trade model from day one. Register at least your top 2–3 SKUs under general trade preemptively, and keep the rest on CBEC. This way, if the Positive List changes, your revenue-critical products can transition smoothly.

If your products use only standard cosmetic ingredients (basic moisturizers, cleansers, makeup), choose CBEC-only entry as a low-cost beachhead. The risk of delisting is significantly lower. However, still budget for NMPA registration of your top seller within Year 2 as insurance and to unlock offline retail channels.

GlowLab’s CEO puts it simply: “CBEC is a door, not a house. Build the house — general trade — while the door is open.”

Key Takeaways for Foreign Brands

GlowLab Korea’s case offers three structural lessons for any brand selling into China via CBEC:

1. The Positive List is not static. Monitor draft updates from the Ministry of Finance and General Administration of Customs at least quarterly. Subscribe to the official gazette feed and work with a China trade compliance advisor who tracks tariff line changes. The 2024 draft was accessible for public comment — GlowLab missed it because no one on the team was monitoring.
2. Ingredient classification is everything. The difference between a product staying on the Positive List and being removed often comes down to how an ingredient is classified — functional vs. general, cosmetic vs. quasi-drug. Work with an NMPA-registered cosmetics assessor to review your formulations against China’s 化妆品安全技术规范 (Cosmetics Safety Technical Standards, huàzhuāngpǐn ānquán jìshù guīfàn) before committing to CBEC.
3. Build redundancy into your China channel strategy. Even if 100% of current sales come through CBEC, invest 10–15% of your China budget in general trade capability — distributor relationships, NMPA filings, bonded FTZ warehousing. This “insurance” cost is far lower than the cost of a sudden channel closure.

NEXT STEPS

Based on GlowLab’s experience, take these three actions to protect your own China market entry:

1. Audit your SKUs against the current CBEC Positive List — Review whether any of your products contain functional ingredients or fall under quasi-drug classifications. Use our CBEC Positive List Compliance Checklist to identify at-risk items before the next update.
2. Start NMPA registration for at least 2 core SKUs now — Even if you are CBEC-only today, the 4–8 month lead time for general trade registration means you must start now to have a backup in place. Download our NMPA Cosmetics Registration Guide for a step-by-step timeline and cost breakdown.
3. Evaluate general trade channel partners — Identify 2–3 distributors or retail partners who can accept general trade imports. This gives you an off-ramp if CBEC access changes. Read our Guide to Korean Beauty Distribution Partners in China for vetted partner profiles.

GlowLab survived the 2025 Positive List changes through rapid action and channel diversification. The brands that thrive in China’s evolving regulatory environment will be those that treat CBEC as one part of a multi-channel strategy — not as the whole foundation.

— China Gateway 360 —
Remote China market entry support, built around execution.