China Allows the Use of Previously Obtained Submission Codes for Compound

On September 4, 2023, China National Institutes for Food and Drug Control (NIFDC) introduced and enforced three Guidelines as follows:

• Technical Guidelines for Filling in and Submitting Safety Information of Cosmetic Ingredients;

• Guidelines for Submitting Information on the Cosmetic Ingredient Safety Information Submission Platform;

• Technical Guidelines for Filling in and Submitting Cosmetic Formula.

With the implementation of these Guidelines, updates were made to the Cosmetic Ingredients Safety Information Submission Platform and the Cosmetics Registration and Notification Information Service Platform. Among these updates, two changes have received significant attention:

1. In the registration and notification process of cosmetic products, the registrant and notifier are no longer allowed to use previously obtained submission codes for compound ingredients to associate ingredient safety information.

2. The Cosmetic Ingredients Safety Information Submission Platform no longer supports the application for new submission codes for compound ingredients that do not have existing codes.

These two changes have generated extensive attention and discussion within the industry, posing challenges for industry’s adaptation in the short term. However, on September 14, 2023, further clarity was provided regarding the use of previously obtained submission codes for compound ingredients.

Allowing the Use of Previously Obtained Submission Codes for Compound Ingredients

On September 14, 2023, the general cosmetics notification system issued an announcement regarding system updates. An improvement was made to the efficiency of notification. Notifiers are now allowed to fill in the previously obtained submission code for compound ingredients to associate ingredient safety information. This update streamlines the notification process and enhances efficiency.

Cosmetic Safety Information Submission Platform Still Does Not Support Applications for New Submission Codes for Compound Ingredients

Since the system upgrade on September 5, 2023, no update announcements have been issued by the Cosmetic Ingredients Safety Information Submission Platform. It still does not support applications for new submission codes for compound ingredients that lack existing codes.

As outlined in the Guidelines for Submitting Information on the Cosmetic Ingredient Safety Information Submission Platform, the platform only accepts applications for ingredients listed in the Inventory of Existing Cosmetic Ingredients in China 2021(IECIC) with single independent serial number. Given that compound ingredients typically comprise multiple serial numbers, they are currently unable to obtain new submission codes through the platform.

During the cosmetic product registration and notification process through the Cosmetics Registration and Notification Information Service Platform, if an ingredient does not have a submission code, registrants or notifiers can fill in the ingredient’s safety-related information and upload scanned copies of paper documents stamped with the seal of the registrant or notifier (Annex 14 of the Provisions for Management of Cosmetic Registration and Notification Dossiers).

Ingredient’s Safety-related Information Required in the Cosmetics Registration and Notification Information Platform

This adjustment in the requirements for compound ingredients effectively shifts the responsibility of providing safety information of compound ingredients from the ingredient supplier to the registrant and notifier, thereby reinforcing their primary accountability for quality and safety.

ChemLinked expects to assist companies in applying for ingredient submission codes and registering/notifying cosmetics in China. If you have any further cosmetic compliance consultation needs, please contact us at [email protected].

Further Reading

• China Implements Guidelines for Submitting Information through the Cosmetic Ingredient Safety Information Submission Platform

• China Finalizes Technical Guidance on Ingredient Safety Information Filling and Submission

• China Implements Technical Guidelines for Filling in and Submitting Cosmetic Formula

• Webinar | China Cosmetic Ingredient Submission Code Application – Latest Updates and Practical Guidance