From January to April 2022, China General Administration of Customs P.R.C. (GACC) revealed a total of eight batches of rejected cosmetics, which were from France, the US, Australia, South Korea, Japan, and Syria. 1 The reasons for the import rejection were:
Unqualified labeling;
Lack of required certificate or quality certificate;
Detection of cannabis sativa seed oil;
Detection of boric acid and borate;
Excessive use of arsenic;
Failing to pass sensory inspection.
Noteworthy Point: Cosmetics Containing Cannabis Sativa Seed Oil Were Rejected
Among the rejected imported cosmetics, an anti-wrinkle facial mask from South Korea was rejected at the Tianjin port due to the detection of cannabis sativa seed oil. This is not the first time that products containing cannabis sativa seed oil or cannabidiol (CBD) have been rejected.
In November 2021, three batches of facial essence oil and handmade soap from the Czech Republic were rejected for containing cannabis sativa seed oil. They were returned or destroyed at Ningbo Port; 2
In February 2021, Quanzhou Customs successively seized three bottles of CBD essential oil, all containing THC ingredients. The relevant suspects have been arrested on suspicion of drug smuggling. 3
Regulatory Status of Cannabis Cosmetics in China
1. General Trade Channel
On May 28, 2021, China National Medical Products Administration (NMPA) implemented the finalized Inventory of Prohibited Ingredients for Cosmetics and Inventory of Prohibited Plant (Animal) Ingredients for Cosmetics, including CBD, cannabis sativa fruit, cannabis sativa seed oil, and cannabis sativa leaf extract as prohibited cosmetic ingredients. From May 28, 2021, cosmetic registrants and notifiers are not allowed to produce or import cannabis cosmetics.
After the ban was promulgated, a Chinese cosmetic brand that once used cannabis sativa leaf extract as its core ingredient announced that it would stop producing cannabis cosmetics. A Chinese leading factory of cannabis cosmetics has also shifted its business focus to fibronectin cosmetics. 4
2. CBEC Channel
Some companies have consulted GACC on whether it is legal to import CBD oil to China through cross border e-commerce (CBEC). GACC replied that its supervision of CBEC products is in accordance with CBEC positive list. CBD oil is not on the positive list, so it is not allowed to enter China through CBEC. A few CBD oil products sold on Chinese domestic e-commerce platforms did not enter China through formal CBEC channels. 5
In addition, if the customs detects that THC is contained in the products labeled with only CBD, it will send the product for further inspection to determine whether it complies with China's anti-drug regulations. 6
ChemLinked Comments
According to Chinese beauty industry media Ju Meili, an industry insider said that the customs have banned cannabis cosmetics from entering China. The customs will review the cosmetic product formula to confirm whether it contains prohibited ingredients such as CBD. 7 The sale or import of cannabis cosmetics carries a high compliance risk in China. Moreover, cannabis cosmetics are quite controversial among Chinese consumers because of their inevitable association with drugs and criminality. It is recommended that cannabis cosmetic companies adjust the product formula and replace cannabis with other alternative ingredients before entering the Chinese market.
If you are interested in the regulatory requirements of cannabis cosmetics in other countries, welcome to visit this news.
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