China Cosmetic Regulations from NMPA

Chinese cosmetics market is the third largest in the global cosmetics industry only after Europe and the United States of America. With an approximate annual growth of 10%, the total value of the Chinese Cosmetics market retail segment is reported to be 260 billion yuan in the year 2018. To leverage the growing market scenario, it is surely a good opportunity for global companies to expand their footprint. But the challenge lies in the increasing competition and the evolving cosmetic regulations of China. Here is a 3600 perspective.

Right now, the National Medical Products Administration (NMPA) is the main Regulatory body of China for cosmetic products. Earlier it was known as the China Food and Drug Administration (CFDA). With an aim to improve and ease the market access; safety and efficacy of the cosmetic products; and post-approval supervision, in the past few years, China has constantly been updating its regulations. The automated filing management system for the registration of imported non-special use cosmetics is only one of them. What are the others? Let’s decode.

China Cosmetics Classification

In China, the cosmetic products are divided into two categories:

  1. Non-Special Use Cosmetics (Non-SUC) – Includes skincare products, haircare products, make-up, perfumes, and nail care products.
  2. Special Use Cosmetics (SUC) – Includes hair related products, depilating products, breast beauty products, sunscreens, and whitening products.

Note: As per the Cosmetic Supervision and Administration Regulation (CSAR), some of the cosmetics are to be reclassified into general cosmetics and SUC.

China Cosmetics Regulations

  • Before entering the Chinese market, products must be registered/notified with the NMPA
  • Depending on the type of product (i.e. domestic/imported), pre-market applications must be submitted by the manufacturers
    • For domestic SUC and imported cosmetics, an administrative license is required
    • For domestic non-SUC, record-filing is mandatory
    • From March 2018, to accelerate the registration process, non-SUC imported from any of the 11 trade-free zones can opt for record-filing instead of the registration process
  • Any new cosmetic ingredient which is not listed in the Inventory of Existing Cosmetic Ingredients in China (IECIC) and is planned to be used in a product, must be registered with the NMPA
  • Ingredients banned as per the Safety and Technical Standards for Cosmetics 2015 will not be approved by the NMPA
  • For pre-market application, a Chinese legal entity (importer, subsidiary or third party) must be appointed by the exporter
  • Product dossiers are required for non-SUC cosmetics which specifies product specifications obtained during the testing of the product at one of the NMPA approved laboratories, which is then submitted to the NMPA
  • Once the filing certificate is obtained, the filing documents’ technical review is carried out within 3 months

China Cosmetics Testing Requirements

  • In China, cosmetic testing is carried out at NMPA approved testing institutions only
  • Hygiene testing is required for administrative approvals which includes sanitary chemical test, microbiological test, toxicological test, and human safety test
  • Animal tests are required only for imported cosmetic products

China Cosmetics Labeling Requirements

Under the regulations of Cosmetic Label Management (former AQSIQ Decree No. 100), a cosmetic label must contain the following information:

  1. Name of the product
  2. Name and address of the manufacturer
  3. Net content
  4. List of ingredients in descending order of concentration, as per their Chinese INCI names
  5. Shelf life and date of production
  6. License of manufacturer, product standard or administrative approval code which is received post the successful registration of the product
  7. Safety marks and precautions
  8. Country of origin, name and address of the distributor, in case of imported products
  9. Usage instructions and storage conditions

The Chinese cosmetics market is becoming a pool of opportunities for companies to tap into. But, to enter, compete and sustain in the market, manufacturers need to ensure end-to-end cosmetic compliance of their products. Therefore, in order to stay ahead of the curve, companies might require specialized Regulatory assistance to stay compliant and to stay up-to-date.