Takehome:
For better implementation of the new system of filing management for first import non-special use cosmetics through Pudong Shanghai, CFDA has released supplementary information relating to renewal of filing certificate.
CFDA has asserted that the current filing certificate which is available in electronic format is exempt from standard renewal and is reason why renewal was not mentioned in the special enforcement rules.
It is still unclear what will happen after the trial period for implementation of this new rule passes. CFDA claimed that they will amend the current regulation based on feedback and experience gained during the trial period and then possibly expand the filing management for import of non-special use cosmetics to the whole country in the future.