A Compendium of China’s New Regulatory Requirements to be Effective and Transitional Policies to Expire in May 2022

The new regulatory requirements to be effective and the transitional policies to expire in May are: 1) Administrative Measures on Cosmetics Labeling will be implemented; 2) Children cosmetics should be labeled with Little Golden Shield and comply with other new requirements; 3) Cosmetics containing newly prohibited ingredients should complete the application for formula change; 4) Previously registered and notified products should complete the document supplementation; 5) Electronic registration certificates will be issued for special cosmetics whose certificate change or renewal has been approved.

On Jan. 1, 2021, China implemented the Cosmetic Supervision and Administration Regulation (CSAR). Afterwards, a series of subsidiary regulations were successively introduced, providing important guidelines for the industry. To help companies adapt to the new regulations, NMPA also issued various transitional policies. Among them, May 1, 2022 is an important node as it marks the end of some transitional periods, and the implementation of some new regulations. ChemLinked sorted out these regulations to help companies make preparations in advance.

1. Administrative Measures on Cosmetics Labeling

On Jun. 3, 2021, China National Medical Products Administration (NMPA) released the finalized Administrative Measures on Cosmetics Labeling (Measures) and will implement it on May 1, 2022. All cosmetics to be registered and notified shall comply with the Measures starting from the implementation date.

The Measures spells out the requirements for labeling and prohibited cosmetic claims under China's new regulations. Cosmetics that have been registered and notified before May 1, 2022 will be granted a transitional period. The registrants and notifiers shall update the labels that not complied with the Measures by May 1, 2023.

Compared with the previous labeling regulations, the Measures has stricter requirements in terms of labeling definition, consistency with registration and notification documents, Chinese labels, product naming, guiding words, etc. For example,