China Introduces Transitional Measures to Implement Cosmetic Supervision and Administration Regulation (CSAR)

After 30 years of waiting, China's new overarching regulation - Cosmetic Supervision and Administration Regulation (CSAR) was finalized on June 29, 2020, and scheduled to be implemented on January 1, 2021. As we are approaching the implementation date and to help stakeholders smoothly transition over to a new regulatory era, China NMPA released transitional measures to help implement the CSAR on December 28, 2020.

The announcement stipulates the transitional measures in the following 7 aspects:

1. Cosmetic Registrants and Notifiers

Starting from January 1, 2021, all enterprises or other organizations that hold a special cosmetics registration certificate (special use cosmetics administrative license) or complete notifications of general cosmetics (non-special-use cosmetics) shall be responsible for the quality, safety and efficacy of cosmetics in accordance with the requirements for cosmetic registrants and notifiers in the CSAR.

2. Registration and Notification

Starting from January 1, 2021, cosmetics and new cosmetic ingredients will be subject to classified management. Prior to the finalization and implementation of the new regulations on registration and notification, cosmetic registrants and notifiers shall submit registration and notification dossiers in accordance with the current regulations, while new cosmetic ingredients registrants and notifiers shall submit the corresponding dossiers according to the Guidance on Application and Review of New Cosmetic Raw Materials. The notification of cosmetics and new cosmetic ingredients will be deemed completed after the submission of notification dossiers. The medical product administration departments will carry out the review on registration and notification in accordance with the procedures and time limit stipulated in the CSAR.

For special cosmetics with a registration decision made after January 1, 2021, the product registration certificate will be valid for 5 years.

3. Five Types of Special Use Cosmetics

Starting from January 1, 2021, the 5 types of special use cosmetics, namely hair growth products, depilating products, breast beauty products, slimming products and deodorants, will no longer be managed as special cosmetics.

The NMPA will not accept relevant registration applications and issue relevant special use cosmetics administrative license. For products with registration applications submitted but not received a registration decision yet;

If the product is newly categorized as a general cosmetic or is not defined as a cosmetic according to the CSAR, the NMPA will terminate the review of the application.
If the product is still a special cosmetic according to the CSAR, the NMPA will continue the review of the application after the applicant submits the updated dossiers.

4. Soap and Toothpaste

Starting from January 1, 2021, soaps that claim to have the efficacy of special cosmetics shall apply for the registration of special cosmetics and obtain a registration certificate in accordance with the CSAR.

Prior to the finalization and implementation of the new regulations on toothpaste, the medical product administration departments will supervise and manage toothpaste in accordance with the current relevant regulations.

5. Efficacy Claim Evaluation and Labeling

Prior to the finalization and implementation of the Cosmetic Classification Rules and Catalog, Standards for Cosmetic Efficacy Claim Evaluation and Administrative Measures on Cosmetics Labeling, cosmetic registrants and notifiers will not be required to disclose the abstract of product efficacy evaluation documents, and the management of cosmetic efficacy claim evaluation and labeling will still be in accordance with the current relevant regulations.

6. Cosmetic Production License

Starting from January 1, 2021, the previously obtained cosmetic production license will still be valid within the validity period. The issuance of a new cosmetic product license and the modification, renewal and re-issuance of an existing cosmetic product license will be subject to the relevant provisions of the CSAR. Prior to the finalization and implementation of the new regulations on cosmetic production license, the application dossiers shall be prepared in accordance with the Practice for Cosmetics Manufacturing Licensing and a new version of the cosmetic production license will be issued for the approved application. In provinces where electronic certificates are issued and used, the electronic certificate will be consistent with the new version of the paper license.

7. Violation and Punishment

The Regulations concerning Hygiene Supervision over Cosmetics is still applicable to violations occurring before January 1, 2021. For violations that are deemed as not illegal or should be given a lighter punishment according to the CSAR, and occur after January 1, 2021, the CSAR shall prevail.

Related Resources:

In order to keep up-to-date on all news concerning CSAR (and the CSAR subsidiary regulations) remember to bookmark and tune in to ChemLinkeds’ comprehensive, and detailed CSAR homepage.

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