China registration

CSAR

Cosmetic Supervision and Administration Regulation

CSAR definition of cosmetics: Daily chemical products intented to be applied on human skin, hair, nails, lips, mouth by spreading, spraying or other similar ways for cleansing, protecting, beautifying or grooming purposes.

 

Cosmetic categories

ORDINARY Cosmetics:

  • Product claims excluded from the functional cosmetics

FUNCTIONAL Cosmetics:

  • Hair dyes

  • Hair perming products

  • Freckle-removing (whitening) products

  • Sunscreens

  • Anti-hair loss products

  • Cosmetics with new efficacy


COSMETIC DOMESTIC RESPONSIBLE AGENT

protectionist concept

Only imported cosmetics are concerned.
The Domestic Responsible Agent (DRA) is mandatory to apply for a NMPA Product Registration in China and must be established in China. NMPA is carrying out rigorous on-site inspections and grading of DRA. Unqualified candidates will not be permitted to act as DRA.

WHO?

Distributor
+ : take care of everything
- : in case of dispute, difficult to regain rights if you want to change: stop of products selling

Consultant
+ : professional regulatory compliance service with low cost; special service menu to meet your individual requirements; more flexible when you choose a local distributor
- : strong inspection from NMPA

Branch Office

+ : 100% under control, professional team to follow up the local regulations.
- : high cost


REGISTRATION

list of ~ 8900 ingredients

Before
→ every 4 years: test and validate products for safe use
→ could not add an ingredient other than those on the list

From May 2021 → lifetime filing certificate
→ if ingredient pre-market registration procedure is approved by NMPA*: "new cosmetic ingredient trial use certificate”
→ if no adverse effects after 3 years = ingredient will be added to IECSC**
→ smoother regulation, allows inspection of ingredients & finished product
→ regulation on animal testing
→ annual report showing the use and safety status of the new raw materials to NMPA through the information service platform within 30 working days before expiration.

*National Medical Product Administration
**Inventory of Existing Chemical Substance


ANNUAL REPORT

In case of new ingredient declaration

In the period of 3 years after the new cosmetics raw materials are registered and put into use, the registrant of the new raw materials shall report the use and safety status of the new raw materials to NMPA every year.

During the safety monitoring period, the registrant shall timely collect and sort out the relevant information in accordance with monitoring requirements, and prepare the annual safety monitoring report accordingly.

Requirements:

  • Basic information & production status of new cosmetics raw materials.

  • Cosmetic product information: supervision, inspection & recall information of the cosmetics containing the new raw materials.

  • Description of risk monitoring & evaluation system applied by the cosmetics manufacturers & the related measures that are taken.

  • The new material registrants shall describe their adverse reaction monitoring systems, statistical analysis & the measures that are taken.

  • For the new cosmetics raw materials that are used at home or abroad for the 1st time, the test data of long-term preservation should be provided in the monitoring period.

EFFICACY CLAIM OF COSMETIC PRODUCTS

When applying for the registration of a cosmetic product, the applicant should upload an abstract of the efficacy claim.

A product classification code based on:

  • The efficacy claim

  • Application site

  • User group

  • Dosage form

  • Usage method

The advertising copy should not be out of the range of product classification and misleading the consumers.

NEW REGULATIONS

Animal testing

China tests on animals at two stages:

  1. Pre-Market Animal Testing: Tests done on products in order to be proven “safe” for consumers before they hit the market.

  2. Post-Market Animal Testing: Tests done after products hit the market. Products can be chosen at random and removed from shelves for “confirmatory” animal testing to ensure that the product on sale to customers is same as formulation approved for sale.

2 preconditions:

  1. General cosmetic manufacturers must have obtained the GMP* certificates issue by the competent authority of the country (region) where they are located.

  2. Safety assessment results must fully confirm the safety of products.

    *Good Manufacturing Practice

3 exceptions:

  1. Products claim to be used for infants and children

  2. Products use new cosmetic ingredients during their 3 years of required monitoring

  3. The responsible person /manufacturer is listed as a key supervision target according to the results of the quantitative rating system established by NMPA

Foreign imported ordinary cosmetics (non-special use)

(NEW) there will NOT be any mandatory pre-market animal testing on Non-SU cosmetics !
But keep in mind, these products can still be subjected to post-market animal testing incase of customer complaints or product recalls.


ADVERSE REACTION REPORT

within 20 working days when they discover the cosmetic adverse reaction

If the cosmetic applicant discovers any risk of their products through the self inspection of adverse reaction, a written report should be submitted to the provincial NMPA and monitoring organization in local.

  • Stop the production and sales of relevant products

  • Notify the OEM factory and dealer to stop the production and sales of relevant products

  • Implement the product recall

  • Release the risk alert

  • Proceed a self audit of production quality management system and rectify the problems

  • Modify the label and instruction

  • Improve the production process

  • Update the registration or filing of relevant products as requirement

  • Other necessary risk control actions

REGULATIONS

Ordinary cosmetics:

  1. Appoint a responsible agent in China

  2. Product dossier

    • The “Cosmetic Registration and Notification Information Form” and related documents

    • Information on the product name

    • Product formula

    • Product executive standard;

    • Product label sample manuscript

    • Product testing report

    • Product safety assessment documents

  3. Submit dossier to NMPA for administrative review

  4. Technical review

  5. Registration certificate

  6. Importation

FUNCTIONAL COSMETICS (special use):

Same steps as ordinary cosmetics
+ The responsible agent applies for NMPA account
+ E-filing certificate

 

INGREDIENTS

  1. Responsible agent information:

    • Responsible registrant person

    • name, address, contact information

  2. New cosmetic ingredient R&D report

  3. Research documents on the NCI* preparation techniques, stability and quality control standards

  4. Safety assessment documents for NCI

  5. Technical requirements (available for public)

High risk NCI:

  1. teratogenicity test

  2. chronic toxicity/carcinogenicity combined

    test

  3. the long-term human trial safety test

    *New Cosmetic Ingredient

Labeling

  1. A complete list of ingredients must be reported on all cosmetic product labels.

  2. Must be in Chinese:

    • Product name

    • Name and address of the manufacturer

    • Net weight/volume

    • Product INCI list

    • Shelf life/expiration date

    • Manufacturer license, product standard or administrative approval

    • Safety marks and product literature, recycle symbols

  3. Prohibited expressions:

    • exaggerated descriptions

    • medical results