On December 26, the China Securities Regulatory Commission (CSRC) issued the "Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (December 22, 2025 - December 26, 2025)". The International Department of the CSRC issued requirements for supplementary materials to a total of 19 companies, among which Proya Cosmetics Co.,Ltd. (603605.SH) was asked to provide additional clarification regarding matters including foreign investment access. According to a disclosure by the Hong Kong Exchanges and Clearing Limited on October 30, Proya Cosmetics Co., Ltd. submitted a listing application to the main board of the Hong Kong Stock Exchange, with China International Capital Corporation Limited and UBS Group AG acting as its joint sponsors.
The CSRC requested that Proya Cosmetics supplement and clarify the following matters, and instructed its lawyers to verify and provide a clear legal opinion: First, clarify whether the intended use of the proceeds from this issuance involves overseas investment, and whether the relevant approval, verification, or filing procedures have been completed. Second, detail the development and operation of products such as APPs, mini-programs, and public accounts by the issuer and its subsidiaries, specifying whether they involve the collection and use of personal information; if so, describe the scale of user information collected and stored, and the data collection and usage practices. Third, as the business scope of the issuer's subsidiaries includes activities such as designing, producing, acting as an agent for, and publishing advertisements, clarify the operational status of the advertising-related business and confirm whether the necessary qualifications and permits have been obtained.
Fourth, regarding foreign investment access: (1) The business scope of the issuer's domestic subsidiaries includes "film production services," "radio and television program production and operation," "online cultural operations," "film distribution," "publication retail," and "performance brokerage," among others; clarify the operational status and compliance of these related businesses, and comprehensively review whether the business scope of all the issuer's subsidiaries involves areas related to "Culture, Sports, and Entertainment" listed in the "Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition)". (2) Beyond the above, further clarify whether the business scope and actual operations of the issuer and all its domestic subsidiaries involve sectors where foreign investment is prohibited or restricted under the "Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition)".
The prospectus reveals that Proya is a local Chinese multi-brand beauty group dedicated to building a world-class cosmetics industry platform, aiming to provide global consumers with cosmetic products that combine technology and high quality. The company has established a multi-brand, multi-category cosmetics matrix covering different consumer segments, spanning skincare, color cosmetics, and personal care. According to data from Frost & Sullivan, based on 2024 retail sales value, the company ranked fifth among the top five groups in the Chinese cosmetics industry, and was the only local Chinese cosmetics group. Measured by retail sales value, the company has been the largest local Chinese cosmetics group for four consecutive years from 2021 to 2024.
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