It is well-known to overseas cosmetics companies who export their products to China that the registration of imported cosmetic for the first time with CFDA need to submit Free Sale Certificates (FSC) issued by authorities or associations in the country of origin, which indicates all foreign cosmetic intended to be placed on the Chinese market must have already been used by consumers abroad.
However, recently CFDA released a letter reflecting stringent examination on the authenticity of FSCs would be carried out because some applicants are found to provide false ones and their products are actually not marketed in the country of origin. CFDA requires cosmetics review expert panel to strictly check the FSC and warn those involved in fraudulence.
Mr. Martin Hu, the cosmetic regulatory expert from REACH24H, told ChemLinked that the issuing units and formats of FSCs vary across different countries, which were acceptable before though. However, things have changed and the expert panel would review the original versions of FSCs which should bear the statement like "xx products have been already sold since xx-xx-xx" or "are sold currently".
This regulatory change does discourage counterfeiting but in the meantime indicates extra compliance duty for those legal applicants since the FSCs potentially need to be updated due to mere format discrepancies.