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China CIQs No Longer Require Label Review on Imported and Exported Cosmetic Products

In a bid to ease the heavy burden of administrative approval on enterprises and stimulate the creativity of the whole industry, on 26 July, the State Council issued Decree No. 638 to abolish and amend a series of national regulations, among which three clauses regarding cosmetics in the

In a bid to ease the heavy burden of administrative approval on enterprises and stimulate the creativity of the whole industry, on 26 July, the State Council issued Decree No. 638 to abolish and amend a series of national regulations, among which three clauses regarding cosmetics in the Regulations for the Implementation of the Law on Import and Export Commodity Inspection (State Council Decree No. 447 of 2005) were therefore revised.    

After amendment, the most significant change is that all imported and exported cosmetics need not go through label review and obtain the label review certificate for port inspection any longer. However, it does not mean that China will loosen the management on labeling of cosmetics because all imported products and special use cosmetics are required to get approval from CFDA before entering the Chinese market and the label is one of the key aspects to look into.   

Besides, in case that companies cannot provide the certificate that proves the imported cosmetic products have been registered with CFDA, the CIQs could report the information about unqualified products to the CFDA, which will take measures to handle the case. 

These policies are made following the institutional reshuffle in March that CFDA has been elevated to a ministerial level and take over more responsibilities from AQSIQ. Martin Hu, a cosmetic regulatory expert from REACH24H, told Chemlinked that the deregulation of AQSIQ on the management of cosmetics is reflective of China government’s determination against bureaucracy, and could be the signal that CFDA consolidates its power on regulating and supervising cosmetics in China.

Nevertheless, since it remains unknown when and how the policies are brought into force, Mr. Hu recommends overseas companies still follow the dual labelling requirements for cosmetics set up by AQSIQ and CFDA respectively (see Chemlinked Expert Article Dual Cosmetic Label Requirements in China-One Step to Take before Entering China Cosmetic Market).

The cancellation of label review is not only a signal of duty integration but also will contribute to simplifying the inspection and quarantine procedures and promoting foreign trade of cosmetics. Under the new leadership headed by Chairman Xi Jinping, several trade facilitation policies are released.

One of the most influential changes is that On 1 Aug, the AQSIQ substantially adjusted the Entry-exit Commodity Catalog Subject to Inspection and Quarantine by Entry-exit Inspection and Quarantine Agencies, which will bring resounding impact on various industries (see Chemlinked news on 29 July). As for the field of cosmetics, it is worth noting that 6 cosmetic ingredients for export are excluded from the “Catalogue”, including peppermint oil (HS: 3301240000), other peppermint oil (HS: 3301250000), citronella oil (HS: 3301292000), anise oil (HS: 3301293000), cassia oil (HS: 3301294000) and litsea cubeba oil (HS: 3301295000). However, cosmetic products are still subject to inspection and quarantine by CIQs.

Another administrative reform that has great impact on overseas cosmetic manufacturers or distributors is that the CFDA has delegated the power of registration of imported non-special uses cosmetic products to provincial FDAs (see Chemlinked news on 27 May).

Reference Links

 Dual Cosmetic Label Requirements in China-One Step to Take before Entering China Cosmetic Market

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