China Introduces Transitional Measures to Implement the New Provisions on Cosmetic Registration and Notification Dossiers

On March 4, 2021, China NMPA released the Provisions for Management of Cosmetic Registration and Notification Dossiers (short for “the Provisions”), spelling out the documentation requirements for the application, modification, renewal, and cancellation of cosmetic registration and notification. The Provisions will take effect on May 1, 2021. ¹

To ensure a smooth transition to the new regulatory regime and help enterprises better cope with new registration and notification regulations, China NMPA released transitional measures in the following five aspects on March 5, 2021. ²

1. Cosmetics Registration and Notification Information Service Platform

A new cosmetics registration and notification information service platform (“new platform”) will be launched for cosmetic registration and notification on the online service hall of NMPA.

• Starting from April 1, 2021, domestic cosmetics registrants, notifiers, domestic responsible persons, and cosmetic manufacturers can submit relevant documents to apply for registration and notification user accounts on the new platform per the requirements of the Provisions.

• As of May 1, 2021, cosmetics registrants, notifiers, domestic responsible persons shall apply for registration of special cosmetics or notification of general cosmetics through the new platform.

  On the same day, the original cosmetics administrative licensing and notification information management system (“original platform”) will no longer accept special cosmetics registration or general cosmetics notification. The applications of special cosmetics registration that have been submitted and accepted on the original platform but have yet to make approval decisions will continue to be reviewed and approved on the original platform.

2. Products that have been registered and notified on the original platform

For cosmetics that have been registered or notified on the original platform, the registrants and notifiers shall submit the product executive standards and product label sample manuscripts, fill in the product formula of domestic general cosmetics, and upload the label picture of the special cosmetics sales packaging through the new platform before May 1, 2022.

3. Submission of information related to the safety of cosmetic ingredients

• Starting from May 1, 2021, when applying for registration or notification, registrants or notifiers shall fill in the source and the trade name of formula ingredients. Among them, if the ingredients have quality specifications in the Safety and Technical Standards for Cosmetics 2015, quality specification certificates or safety-related information of the ingredients shall also be submitted.

• Starting from January 1, 2022, when applying for registration or notification, registrants or the notifiers shall provide safety-related information of preservatives, sunscreens, colorants, hair dyes, freckle removing and whitening ingredients per the requirements of the Provisions.

• Starting from January 1, 2023, when applying for registration or notification, registrants or the notifiers shall provide safety-related information of all ingredients per the requirements of the Provisions. For cosmetics that have been previously registered or notified, the registrant and notifier shall supplement safety-related information of all the ingredients in the product formula before May 1, 2023.

4. Efficacy evaluation testing report of freckle removing (whitening) and anti-hair loss cosmetics

• Starting from January 1, 2022, when applying for the registration of freckle-removing (whitening) and anti-hair loss cosmetics, registrants shall submit a human body efficacy evaluation testing report that meets the requirements of the Provisions.

• For freckle-removing (whitening) and anti-hair loss cosmetics that have been registered before May 1, 2021, the registrants shall supplement a human body efficacy evaluation testing report before May 1, 2023.

• For freckle-removing (whitening) and anti-hair loss cosmetics that have been registered between May 1, 2021, and December 31, 2021, the registrants shall supplement a human body efficacy evaluation testing report that meets the requirements of the Provisions before May 1, 2022.

5. Annual Reporting of General Cosmetics

Starting from January 1, 2022, the annual report system will be implemented uniformly for general cosmetics notified through the original platform and the new platform. Notifiers shall submit the annual report of general cosmetics notified over one year through the new platform from January 1 to March 31 of each year.