Speciality Chemicals Magazine MAY / JUN 2024 | Page 55

COSMETICS & PERSONAL CARE
• The product formula only contains ingredients that have passed the three-year monitoring period and have been included in the Inventory of Existing Cosmetic Ingredients ( IECIC ) of 2021
• The filer or registrant is not subject to supervision by the NMPA According to the CSAR regulation , the safety information of cosmetic ingredients used in the product formula of perfume and makeup should be reported to the NMPA before applicable deadlines . There are two ways to report the information :
• The filer or registrant can complete Annex 14 for each ingredient and submit it with the filing or registration dossier .
• The supplier of the cosmetic ingredients responsible for their safety can generate a code on the NMPA safety information platform and share it with downstream filers and / or registrants
Ordinary cosmetics ( filing )
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Appointment of DRP
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Filing account set-up
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Testing
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Dossier preparation
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Submission
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Format review ( 5 days )
E-certificate
Figure 2 – Filing & registration process for cosmetics imported into China
Technical review spotcheck will carried out at a later time for ordinary cosmetics
Import to China
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Special cosmetics ( registration )
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Appointment of DRP
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Registration account set-up
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Testing
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Dossier preparation
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Submission
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Format review ( 5 days )
Technical review ( 90 days )
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Registration certificate
Practical tips
Firstly , create an inventory list of perfume and makeup products manufactured or traded by your company . Figure 3 gives examples of terms used .
Next , determine the classification of your product in China . In general , perfumes and makeup products are considered ordinary cosmetics but there are some exceptions if they have a special claim . These include foundation with SPF 30 , nail glitter for children and SPF lip balm . Further steps needed are to :
• Determine the management type based on the classification : filing management ( ordinary ) or registration management ( special )
• Determine if you have a DRP in China or contact a third party , such as CIRS , for this service
• Consider if waiving animal testing is a priority . Remember , this only applies to ordinary cosmetics that meet certain exemption criteria , as discussed above
• Check with your raw material suppliers if they have NMPA safety information codes or are willing to share the safety information with you to fill in Annex 14 for each raw material in the product formula
Summary
Perfume and makeup products from the EU remain very popular in China . Therefore , companies should be aware of the regulatory requirements before importing to China . Perfume and makeup products are classified as ordinary cosmetics unless they have a special function claim . Their management , be it filing or registration , is subject to their classification .
The advantage of filing management includes waiving the animal testing requirement under certain conditions and reducing authority review time before compliantly introducing the products to the Chinese market . If there is a special claim , animal testing is mandatory and a full technical review by the NMPA is required before import and sale to China . ●
Figure 3 – Terms commonly used to define cosmetics in China
Perfumes
Makeup
Perfume / parfum
Skin makeup ( foundation , concealer , blusher , highlight , bronzer )
Esu de parfum
Eye makeup ( eyeshadow , eyeliner , mascara )
( EDP ) Eau de tolette
Lip makeup ( eyebrow pencil , eyebrow gel )
Eau de Cologne
Eyebrow makeup ( eyebrow pencil , eyebrow gel )
Eau fraiche
Nail makeup ( nail , polish , nail glitter )
Note : They should also meet the definition of cosmetic according to the CSAR regulation
Julie Harrington
SENIOR REGULATORY CONSULTANT
CIRS k + 353 1477 3708 J julie @ cirs-reach . com j www . cirs-reach
MAY / JUN 2024 SPECCHEMONLINE . COM
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