Key takeaways
- For cross-border sellers, the limit for this year’s 11.11 shopping festival is not traffic but warehouse entry: whether a bonded warehouse can accept the goods and whether customs will release them directly determines how much you can sell.
- The documents most likely to delay replenishment are the certificate of origin and the free sale certificate. Both have shifted from post-admission supplementation to pre-entry submission; missing documents cannot be added later.
- Products containing key regulated ingredients must have all three required certificates. Declared information must match the filing certificate, overseas formulation statement, third-party test report, Chinese label and physical product in all five places; otherwise, the goods may be returned.
Why Replenishment Must Start Earlier This Year
After last year’s 618 shopping festival, cross-border importers encountered three recurring problems: goods were returned at the port, held in the customs area for review, or admitted into the zone but unable to go live in inventory. The common issue was not weak sales, but the failure to convert goods into sellable inventory on time.
In 2026, entry supervision for cross-border supplements, cosmetics, infant formula and other categories continues to tighten. After media reports in August this year again highlighted counterfeit overseas brands in the cross-border supplement sector, the stricter inspection trend at ports became even clearer. For brands, this changes the logic of promotion replenishment: the priority is no longer simply securing warehouse capacity and transport, but first confirming whether the shipment’s documents can clear customs.
Based on this year’s announced schedule, JD.com’s 11.11 shopping festival begins selling ready-stock goods at 8 p.m. on October 12; Tmall opens deposit payments at 8 p.m. on October 15, with final payments and ready-stock sales starting at 8 p.m. on October 20; and Douyin Mall’s 11.11 campaign runs from 12 a.m. on October 15 to 24:00 on November 11. Supplementing documents at that point leaves very little time.
Six Entry-Document Checks
First, notarized documents for the overseas entity and proof of a domestic jointly liable entity. These are basic platform requirements for identifying the responsible parties, and both are mandatory.
Second, an overseas R mark. Platform requirements are increasingly aligned, and TM marks are no longer accepted.
Third, brand authorization documents covering no more than three levels. The authorization chain must be continuous and traceable.
Fourth, a certificate of origin or free sale certificate. This is the biggest change this year: some platforms previously allowed these documents to be submitted after admission, but they are now required in advance. Complete official compliance documents from the country of origin must be provided when the goods enter the warehouse.
Fifth, a continuous, unedited video showing offline sales overseas. The video must cover the store’s surrounding environment, entry into the store, shelf displays, product selection and payment, and must include the shopping receipt and store address. This is a direct measure targeting counterfeit overseas brands and fabricated overseas business backgrounds.
Sixth, the basic materials required for onboarding review by cross-border e-commerce platforms. Platform requirements vary, so it is advisable to prepare one standardized document set based on the strictest requirements.
Key Regulated Ingredients: Check This List First
Customs has established a list of key regulated ingredients. At present, the list contains approximately 20 ingredients, including NMN, melatonin, coenzyme Q10, glutathione, quercetin, PQQ, ashwagandha, resveratrol, ergothioneine, alpha-lipoic acid, 5-HTP, DHEA, astaxanthin, curcumin, magnesium glycinate, phenylalanine, tryptophan, inositol and L-carnitine. The list is adjusted dynamically based on risk-monitoring results; the latest notices issued by customs prevail in practice.
Products containing ingredients on the list must have all three required certificates, regardless of whether they use general trade or a cross-border channel: a certificate of origin issued by an official authority in the country of origin, a free sale certificate issued by the competent authority in the country of origin, and an official food-use basis or compliant-use certificate from the country of origin. None of the three may be missing.
Before introducing a new product or replenishing inventory, compare the ingredient list against the regulatory list item by item. If the product contains a listed ingredient, assess in advance whether the required compliance documents from the country of origin can be provided. Also ensure that test reports and certificates of origin are genuine and valid, avoiding mislabelled ingredients or exaggerated claims.
Full-Ingredient Declarations: Five Points Must Match
From 2026, full-ingredient declarations for imported supplements bring excipients within the mandatory scope, creating closed-loop control over both active ingredients and excipients. Companies must declare all excipients, and the information must match exactly across five points: the registration or filing certificate, overseas formulation statement, third-party test report, Chinese label and actual product.
Any discrepancy may be deemed an inaccurate declaration and create a risk of return. In practice, the most common issues are not errors in the formulation itself, but differences between the Chinese label and overseas documents in ingredient order, units of quantity or excipient names.
Red Lines for Product Pages and Livestream Scripts
Getting the product into the market is only the first step; the claims must also be accurate. Permitted health-function claims are governed by the official catalogue. From January 1, 2026, “helps maintain bone and joint health” was added, bringing the current total to 25 claims. Statements outside the catalogue, as well as any treatment-oriented language, are violations.
Also note that the Measures for the Supervision and Administration of Livestream E-Commerce take effect on February 1, 2026. Livestream selling is explicitly included within the scope of commercial advertising, and drugs, health foods and medical devices may not use advertising endorsers to recommend or certify products. This narrows the space for influencer distribution of cross-border supplements, making self-operated livestreams and brand content the mainstream routes.
One-Page Self-Check List
Before launching the promotion, complete the following actions: confirm that all six entry-document categories are complete; compare the ingredient list with the key regulated-ingredient list and verify the three required certificates; check that declaration information matches the label and test report; review product-page copy and livestream scripts to ensure they stay within the health-function catalogue; and reserve at least one month of manual document-review buffer for priority SKUs.
Frequently asked questions
Which document is most often missing when cross-border supplements enter a bonded warehouse?
The most commonly missing documents are the certificate of origin and the free sale certificate. Both have shifted from post-entry submission to pre-entry submission. Once the goods arrive at the port, it is already too late to add them, which directly extends the replenishment cycle and creates hidden costs such as first-mile transport, port demurrage and warehouse fees.
Do products containing key regulated ingredients need the three required certificates when sold through a cross-border channel?
Yes. The rule for the key regulated-ingredient list applies “regardless of whether the goods use general trade or a cross-border channel.” Any product containing a listed ingredient must provide a certificate of origin, a free sale certificate and an official food-use basis from the country of origin.
How much buffer should be built into the replenishment schedule?
Under the new rules, manual document review is more likely. Plan to start one to one and a half weeks earlier than usual, and reserve more than one month of review buffer for priority SKUs. For ocean-freight batches, incorporate the probability of inspection directly into the schedule.
Is a continuous, unedited overseas offline-sales video mandatory?
On major cross-border platforms, it is commonly a mandatory material in the brand-verification process and is used to verify that the brand genuinely operates in overseas markets. Online channels may also be substituted with screenshots of sales pages on major international e-commerce platforms and product links showing sales volumes and reviews. The platform’s rules in effect at the time prevail.
Discussion
Share a practical question or perspective. Plain text only; every comment is reviewed before publication.
Want to discuss your operating scenario?
Tell us what you are trying to connect, measure or improve.
No published comments yet. Start the discussion.