Breaking! China to Release New Inventory of Existing Cosmetic Ingredients (IECIC 2021 Edition)

On January 26, 2021, China National Institutes for Food and Drug Control (NIFDC) released a draft of the new Inventory of Existing Cosmetic Ingredients in China (hereinafter referred to as the “draft IECIC”) for public comments. ¹ The deadline for the consultation is February 18, 2021. Stakeholders with any suggestions can fill out the feedback form and send it back by email at [email protected] with supporting materials enclosed. Paper materials shall also be mailed to NIFDC.

Recipient: Safety Evaluation Room of Cosmetics Inspection Institute, China NIFDC
Address: No. 2, Tiantan Xili, Dongcheng District, Beijing
Tel: 010-67095881

Introduction of IECIC

IECIC is a comprehensive collection of ingredients that have been used in cosmetics produced and sold in China. It serves as the sole reference for determining the regulatory status of cosmetic ingredients. All ingredients excluded from the Inventory are deemed "new ingredients" and subject to mandatory pre-market registration or notification with the NMPA under new cosmetic regulations.

It was first introduced in 2014 and last updated in 2015. The existing IECIC 2015 encompasses a list of 8783 cosmetic ingredients. The draft IECIC increases the total number of existing cosmetic ingredients to 8980.

Main Amendments of the Draft IECIC

1. Newly increases the information of ingredients’ highest historical use concentration

Based on the information of all ingredients used in formulas of the special use cosmetics and imported general cosmetics approved from 2010 to March 2020, the highest historical use concentration of different ingredients is clarified and newly added to the IECIC.

For example, the highest historical use concentration of the moisturizer 1,2-Butanediol in rinse-off and leave-on products is 8% and 6%, respectively. The highest historical use concentration of the surfactant 3-Aminopropane Sulfonic Acid in rinse-off and leave-on products is 1% and 0.3%, respectively. In cases where the ingredients in the Inventory only have the highest historical use concentration for leave-on products, the rinse-off products shall be used with reference to the limits for leave-on products.

It is worth noting that the use concentration of ingredients in the IECIC will provide a great reference value and technical support for cosmetic enterprises to conduct cosmetic safety risk assessments. In the future , if the product’s ingredient content exceeds the given limit, the safety of the product may be questioned, and other supporting documents may require submission.

2. Makes some supplements and revisions to the IECIC 2015

Types of Amendments	Details of the Amendments	Examples
(1) 197 ingredients are newly added.	The draft IECIC adds 7 cosmetic ingredients that have previously passed the review of new cosmetic ingredient registration.	Include Hump Oil, Elaeagnus Mollis Diel Oil, Glabridin, Ethyl Lauroyl Arginate HCL, Methoxy Peg-23 Methacrylate/Glyceryl Diisostearate Methacrylate Copolymer, Calcium Phosphoryl Oligosaccharides, Steareth-200.
	The draft IECIC adds 125 restricted ingredients, preservatives, sunscreens, colorants, and hair dyes that are listed in the Safety and Technical Standards for Cosmetics 2015 (STSC) but are not included in the IECIC.	Include but are not limited to Alkyl(C12-C22) Trimonium Chloride, Saccharinate, Oxyquinoline Sulfate, Polyacrylamides, Trialkylamines, Trialkanolamines and Their Salts, Quinine and Its Salts, Selenium Disulfide, Diaminopyrimidine Oxide, Dimethylol Ethylene Thiourea, Lithium Hydroxide.
	63 specific ingredients are supplemented to the original group ingredients, consisting of 3 kinds of plankton extracts, 4 kinds of brown algae, 27 kinds of algae extracts, 9 kinds of orchid extracts, 9 kinds of vegetable oil, and 11 kinds of hydrogenated vegetable oils.	Include but are not limited to Anacystis Nidulans Extrac, Monostroma Nitidum Powder, Eucheuma Serra Extract, Dendrobium Chrysotoxum Extract, Peach Oil, Cottonseed Oil, Hydrogenated Canola Oil.
	The draft IECIC adds 2 extended ingredients for different parts of plant extracts.	Melia Toosendan Bark/Root Bark Extract, Lepidium Apetalum Seed Extract.
(2) 7 ingredients are deleted.	The draft IECIC deletes 4 ingredients with duplicate ingredient names.	Acrylates/Behenyl Acrylate/Dimethicone Methacrylate Copolymer, Citrus Aurantifolia (Lime) Fruit Extract, Litchi Chinensis Seed Extract, And Rosa Rugosa Flower Extract.
(2) 7 ingredients are deleted.	The draft IECIC deletes 3 ingredients without histories of use and clear sources.	“黑蚂蚁(Silky ant)," "龙脑香(Kapur)," "蛇麻子(Hop)."
(3) The draft IECIC newly adds remarks for 50 ingredients, indicating that these ingredients are to be included in the draft *Inventory of Prohibited Cosmetic Ingredients*. (View an Example)		Include but are not limited to 2,4-Diamino-5-Methylphenoxyethanol HCl, 2,4 -Diaminophenol, 2,4-Diaminophenol HCl, 4-Nitroguaiacol, etc.
(4) The Chinese/English/INCI name of a batch of ingredients are adjusted and standardized.	In the IECIC 2015, there are 20 plant ingredients that have one ingredient serial number corresponding to two Chinese names. According to the International Cosmetic Ingredient Dictionary and Handbook, Chinese Pharmacopoeia and the Flora of China, etc., the draft IECIC retains the standardized one of the two names and alters the other to the "former name." (View an Example)	Include but are not limited to Allium Tuberosum Seed Extract, Litchi Chinensis Extract, Campsis Grandiflora Extract, Artemisia Annua Extract, Crataegus Pinnatifida Fruit Extract. *Notably, when these plant ingredients are used in cosmetics, it is recommended to use the standardized Chinese name rather than the Chinese name with the note of "former name."
	Ingredients with clerical errors and ingredients lacking English name in the IECIC 2015 are adjusted and supplemented.	For example, the ingredient “α-甲基紫罗兰酮” supplements an English name “α-Methyl Ionone."
	According to the International Cosmetic Ingredient Dictionary and Handbook, Chinese Pharmacopoeia, and the Flora of China, the Chinese/English/INCI names of some ingredients are revised and standardized.	For example, the English name of "Ananas Sativus Extract" is changed to "Ananas Sativus (Pineapple) Extract."

ChemLinked Comments

This revision aims to deal with the considerable inconsistency between the content of the IECIC 2015 and the requirements of new cosmetic regulations , further standardize the management of cosmetic ingredients, and lay the foundation for the implementation of the new cosmetic ingredients notification system.
From the approval of the first batch of 4 new ingredients to the adjustment of the prohibited ingredient list, and then to the revision of the IECIC, the Chinese cosmetic regulatory departments’ control measures towards cosmetic ingredients are gradually enforced. It is a clear sign that China is giving increasing weight to the management of ingredients. ChemLinked expects that there will be more ingredient-related revisions in the future.
Once these lists take effect, cosmetics companies will face the burden of a heavy workload. They must recheck all the original products per the new IECIC and prohibited lists and change the registration/notification and packaging.