China Cosmetic Adverse Reaction Monitoring in Need of a Makeover

Despite China’s growing demand for cosmetics with diversified functions, the country currently lacks an efficient system to deal with adverse reactions arising from the numerous new cosmetic products introduced every year. According to research by Chenxing, inspection staff from a local FDA in Shandong Province, China’s future reform of adverse reaction monitoring system will focus on four key areas.

Fill in the Legislative Gap

Adverse reaction monitoring remains a vague concept in China’s overarching “Regulation of Cosmetic Hygiene Supervision”, with no clear definition or designated regulatory authorities. China’s standard regulatory strategy begins with introduction of new laws or regulations before other support measures are introduced to improve practical implementation. Adverse reaction monitoring is standard practice in the regulatory frameworks of the EU, US etc. and as such we can expect China’s system to closely model these systems.

Build an Interactive Monitoring Network

Rapid dissemination of information between the relevant links in the cosmetic supply chain is crucial in any efficient adverse reaction monitoring and response system.  Any monitoring system is only as effective as the communication speed and response time of the various elements which can include medical institutes, cosmetic manufacturer and distributors, NGOs and consumers. An immediate solution would be to create a public notification institution that keeps consumers updated on the occurrence of any cosmetics associated with adverse reactions and publicly report the product name and the producer via media or other social networking methods.  Such a system could integrate with the existing IT infrastructure used in the online application system for cosmetic application and recordkeeping to provide a comprehensive traceability system for China’s cosmetic supply chain.

Restructure Regulatory Authorities

China has now set up inspection and testing institutes at city level to carry out inspection and testing of cosmetics. The next step would be to further clarify the duties of those institutes and ensure substantive implementation of revised legal guidance and standards to avoid bureaucratic redundancy. This would require restructuring of the governing institutions which should be divided into four segments of responsibility: project management, staff allocation, liability tracking and report compilation.

Enhance Public Education

According to the results from a survey conducted last on “cosmetic safe use” conducted by the food and drug inspection and testing institute in Binzhou, Shandong Province, of 415 people interviewed, only 20.24 % reported that they would lodge a complaint to relevant government department if they were affected by adverse reactions from cosmetics. The fact that the majority chose to remain silent is largely attributed to lack of education on cosmetic adverse reaction. To ensure consumer safety, public education must be a part of any future reforms, and that would demand involvement of industry and government together.