China’s New Standards of Cosmetics Registration, Filing, and Inspection Announced

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On September 10, China’s National Medical Products Administration (NMPA) released a Circular on the Standards of Cosmetics Registration, Record-Filing, Inspection and Test (NMPA Circular [2019] No.72).

The Circular No.72 updates the registration, record-filing, inspection and test items of cosmetic products and stipulates that qualified laboratories can register themselves in the NMPA’s management system to take charge of cosmetics registration, record-filing, inspection and tests.

New management system will be online

Previously, cosmetics manufactured in China were required to undergo inspection and tests in laboratories designated by the China Food and Drug Administration (CFDA). (A total of 35 designated laboratories can be found in the official website of CFDA.)

From November 1, 2019, these CFDA-designated laboratories will not be allowed to conduct cosmetics registration, record-filing, and inspection.

Instead, from September 10, eligible laboratories must submit relevant information to a new online system – Cosmetics Registration, Record-Filing, and Inspection Management System – to be registered to undertake cosmetics registration, record-filing, and inspection.

The NMPA will publish the name, address, contact information, and competence scope of the qualified laboratories online. Then, cosmetics enterprises can query relevant information of the laboratory online and select one with corresponding inspection capabilities to carry out the registration, record-filing, and inspection of the cosmetic product.

Adjustment of the inspection and test items

The Circular has adjusted the original cosmetic inspection and test items in hygiene, pathology, human body safety, and efficacy evaluation inspection and other aspects.

Cosmetic enterprises and inspection institutions shall refer to Annex 1 of the Circular No.72 to identify inspection items of the cosmetic product.

Transitional period under the new Circular

Between September 10 and October 31, 2019, cosmetics enterprises can either select a laboratory that has been published on the NMPA system to finish cosmetics registration, record-filing, and inspection online or follow the original procedures, offline, through a CFDA-designated institution.

For cosmetics registered or recorded after September 10 that haven’t been tested, the inspection and tests must be carried out as per the new standards in the Circular.

If the inspection and tests have already been undertaken or an overseas laboratory has completed the inspection and issued an inspection report, the report can be used in the registration or filing of cosmetics.

Products that were registered or recorded before September 10, but whose inspection items are inconsistent with standards specified in the Circular – will require their inspection to be supplemented within one year.

Further, the supplementary inspection report must be submitted at the time of the application for extension of the validity of the product’s administrative license or provided for future reference when the product is put on record to confirm the continuation of production.


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