Breaking! China Launches the Long-Awaited Submission Platform for Cosmetic Ingredients Safety Information

Background

The Provisions for Management of Cosmetic Registration and Notification Dossiers, one of the significant subsidiary regulations of the Cosmetic Supervision and Administration Regulation, puts forward relevant provisions on the submission of cosmetic ingredients safety information, which requires that:

• Starting from January 1, 2022, the newly registered or notified cosmetics shall provide safety-related information (ingredient safety information documents or the ingredient submission code) of preservative, sunscreen, colorant, hair dye, freckle removing and whitening ingredients.

• Starting from January 1, 2023, when applying for registration or notification, registrants or the notifiers shall provide safety-related information of all ingredients. For cosmetics that have been previously registered or notified, the registrant and notifier shall supplement safety-related information of all the ingredients in the product formula before May 1, 2023.

However, the ingredient submission code can only be generated after the cosmetic ingredient manufacturer or its authorized enterprise submits the ingredient safety information on the online platform designated by NMPA. Therefore, when the platform will be launched has been a major concern in the industry in recent months. Stakeholders have been waiting anxiously for it.

New Submission Platform

On December 30, 2021, China NMPA officially issued a notice on the launch of the Cosmetic Ingredient Safety Information Submission Platform (hereinafter referred to as "the submission platform"), announcing that from 9 a.m. on December 31, 2021, cosmetic ingredient manufacturers or their authorized companies can log on to this platform, and submit ingredient safety-related information to obtain an ingredient submission code.¹

• Login method

Domestic users can directly log in the submission platform. Overseas users shall first open an account on the Cosmetic Ingredient Safety Information Submission Platform and then log in.

• Transitional management

After the launch of the submission platform, cosmetics registrants, notifiers, and domestic responsible persons can:

• still fill in the ingredient safety information documents provided by the ingredient manufacturer through the cosmetics registration and notification information service platform; or

• fill in the ingredient information submission code generated by the cosmetics ingredient safety information submission platform to associate with the ingredient safety information document.

Technical Guidance on Submission

Along with the notice, a Technical Guidance for Submission of Cosmetic Ingredients Safety Information (hereinafter referred to as “the Technical Guidance”) was issued to guide enterprises in the correct use of the submission platform and standardize the submission of cosmetic ingredient safety information.

The Technical Guidance is composed of five parts: "Enterprise Information," "Ingredient Classification and Key Features Ticking," "Filling in Ingredient Safety Information," "Generation of Ingredient Submission Code," "Use of Ingredient Safety Information," and four annexes.

The main points of the Technical Guidance are as follows (ChemLinked translation will be uploaded soon):

1. Subjects of submission

Cosmetic ingredient manufacturer refers to the enterprise responsible for the safety of ingredients. It can be 

• the actual production enterprise of ingredients, 

• the affiliated enterprise belonging to the same group company as the actual production enterprise of ingredients, or 

• the entrusting enterprise engaged in the entrusted production of ingredients.

Cosmetic ingredient manufacturers can submit cosmetic ingredient safety information by themselves, and they can also authorize other overseas or domestic legal entities to submit and maintain the information, such as their ingredient distributors or third-party compliance companies like ChemLinked's founder, REACH24H.

2. Required enterprises information

The cosmetic ingredient manufacturer or its authorized companies shall fill in the Enterprise Information Form and upload 1) the scanned copy of the Enterprise Information Form, 2) the enterprise entity certification documents of the ingredient manufacturer, and 3) the authorization letter issued by the ingredient manufacturer (in the case of authorized submission). After all the required enterprise information is submitted, a unique manufacturer code will be generated.

Notably, the "ingredient manufacturer name" in the Enterprise Information Form is an important basis for identifying the enterprise's identity and assigning the code of the ingredient manufacturer. It should be filled in in a standardized and accurate manner, consistent with the content contained in the enterprise entity certification documents.

3. Required ingredient information

The ingredient safety information to be filled includes basic information and brief descriptions of production process, ingredient identification and characteristic indicators, risk information and control indicators, assessment conclusions of international authoritative institutions, brief description of use requirements for use in other industries, and other issues that need to be explained.

In the basic attribute column of the ingredient, the following items should be ticked, including the basic characteristics of the principal component, the source of the ingredient, the production method of the ingredient, other characteristics, and the reason for the compounding/mixing of the compound/mixed ingredient.

4. Ingredient submission code

After filling in the ingredient safety-related information as required, a corresponding ingredient submission code will be automatically generated. The ingredient submission code consists of three parts: "ingredient code-manufacturer code-quality specification code." Some of the code numbers are randomly allocated.

After submission, the ingredient submission code and ingredient safety-related information will be automatically synchronized to the special cosmetics application and review system, the general cosmetics notification management system, and the publicity system.

ChemLinked Comments

1. The introduction of the ingredient submission code and the launch of the submission platform allow downstream cosmetic factories or brands to directly associate ingredient safety information by filling in the code when applying for registration or notification online. This can significantly save time for sorting and uploading ingredient-related documents by themselves so as to simplify the process of registration and notification and improve work efficiency. Meanwhile, it also reduces a lot of communication costs for ingredient suppliers.

2. From the perspective of supervision, the significance of the launch of the submission platform is to ensure the full traceability of cosmetic ingredients and achieve more comprehensive product lifecycle stewardship.

   Some industry experts point out that the supervision of cosmetic ingredients is an essential link of product supply chain management. Previously, the ingredient market in China was not well-regulated. There are many chaos phenomena such as shoddy products, unauthorized changes of manufacturers, and forgery of COA and MSDS, etc. However, with the launch of the submission platform, each ingredient has its own "ID number," which guarantees the safety of cosmetics from the source. If there is a problematic ingredient, the supervision departments can trace back from the platform which formula is associated with the ingredient in a timely and direct manner, instead of letting the company report it after self-inspection.

3. In addition, it shall be noted that although overseas enterprises can log in to the submission platform directly, they need to be equipped with staff who understand Chinese or entrust a third party to perform related operations on the platform, given that the platform interface and related operation instructions are all in Chinese.

   *ChemLinked provides services to help brands in cosmetic safety information submission. If you have any questions or further cosmetic compliance consultation, please feel free to contact us at [email protected].