Editor's Note: This article was originally published on May 17, 2023, and was updated on September 4, 2023, as per the latest developments.
On September 4, 2023, China National Institutes for Food and Drug Control (NIFDC) approved the Guidelines for Submitting Information through the Cosmetic Ingredient Safety Information Submission Platform. 1
On May 12, 2023, China National Institutes for Food and Drug Control (NIFDC) initiated a public consultation on the Guidelines for Submitting Information through the Cosmetic Ingredient Safety Information Submission Platform (the Guidelines). Any suggestions can be sent to firstname.lastname@example.org by May 31, 2023. 2
The objective of developing the Guidelines is to provide guidance to ingredient manufacturers on the correct use of the Ingredient Safety Information Submission Platform (the Platform) and standardize the submission of ingredient safety information. The Guidelines consists of 13 Articles, including the basis, purpose, application scope, submitting entity, submission content, the generation and use of ingredient submission codes, etc.
The Platform is exclusively applicable to the submission of safety information for ingredients that are listed in the Inventory of Existing Cosmetic Ingredients in China 2021 (IECIC) with independent serial numbers.
There are varying interpretations of this requirement within the industry. One perspective is that this requirement excludes group ingredients listed in IECIC, implying that safety information can only be submitted for specific ingredients under the group ingredient.
Another viewpoint is that the Guidelines applies solely to the submission of safety information for a single ingredient, and it remains unclear whether and how to submit the safety information for compound ingredients.
Clarifying the submission principles
Ingredient manufacturers must submit safety information in accordance with relevant regulations and technical specifications, and be responsible for the authenticity and completeness of the information. They can either submit the safety information themselves or authorize Chinese domestic or foreign legal entities to submit and maintain it. However, for ingredients with the same quality specification, only one enterprise can be authorized to submit the safety information.
Clarifying necessary documents for submitting ingredient safety information
The Guidelines clarifies the necessary documents for registering an account and submitting the ingredient safety information on the Platform.
1. Register a platform account