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China NIFDC: Advertising “Ingredient Submission Code Obtained” Suspected of False or Exaggerated Publicity

On October 27, 2022, China National Institutes for Food and Drug Control (NIFDC) released an announcement answering a question related to the generation of cosmetic ingredient submission code. [1] It emphasizes that using terms such as "ingredient submission code obtained" to falsely claim that the ingredients have been approved or recognized by regulatory authorities is suspected of false or exaggerated publicity, and will be investigated and punished.

Background

The Provisions for Management of Cosmetic Registration and Notification Dossiers, one   of the significant subsidiary regulations of the Cosmetic Supervision and Administration Regulation (CSAR), puts forward provisions on the submission of cosmetic ingredients safety information, which requires that:

  • Starting from January 1, 2022, the newly registered and notified cosmetics shall provide the safety information (ingredient safety information documents or the ingredient submission code) of preservative, sunscreen, colorant, hair dye, as well as freckle removing and whitening ingredients;

  • Starting from January 1, 2023, when applying for product registration or notification, registrants/notifiers shall provide the safety information on all ingredients. For cosmetics previously registered or notified, registrants/notifiers shall supplement the safety information of all ingredients in the product formula before May 1, 2023.

 

On December 31, 2021, the Cosmetic Ingredients Safety Information Submission Platform came into service. Cosmetic ingredient manufacturers or their authorized companies can log on to the platform to apply for ingredient submission codes. As of November 10, 2022, the platform has recorded 174,242 pieces of ingredient submission code information.

NIFDC’s Answer to Question Related to Ingredient Submission Code

Q: How to generate ingredient submission code on the Cosmetic Ingredient Safety Information Submission Platform?

A: The Cosmetic Ingredient Safety Information Submission Platform (hereinafter referred to as the “platform”) is mainly used for ingredient companies or their authorized companies to submit ingredient safety information. After completing the information submission, the platform will automatically generate an ingredient submission code. Cosmetic product companies can use the code to link the products with relevant ingredient safety information. The platform can greatly simplify the product registration and notification process, especially for the same ingredient used in multiple products, avoiding repeated submissions of quality and safety information.

It is worth noting that the platform is only an information-based means to improve the efficiency of cosmetic registration and notification. Ingredient companies and product companies using the ingredient shall assume the responsibility for ensuring the legality, authenticity, accuracy and completeness of ingredient safety information. The regulatory authorities do not organize the review or approve of the ingredient safety information submitted to the platform. Completing the ingredient safety information submission and obtaining the ingredient submission code does not mean that the ingredient has been approved or recognized by the regulatory authorities.

Therefore, the following behaviors are suspected of false or exaggerated publicity, and will be investigated and punished by relevant regulatory authorities: (1) Using terms such as "ingredient submission code obtained" to falsely claim that the ingredients have been approved or recognized by regulatory authorities; (2) Fabricating a trade name that does not belong to the scope of cosmetic ingredients, such as “xx exosome” for ingredient promotion.

Industry Comments

According to Chinese Industry Media Qingyan, the obtaining of the ingredient submission code has become an important criterion for selecting ingredient suppliers. Some companies used “ingredient submission code obtained” as a gimmick, claiming that their ingredients are officially approved, safe and reliable. For example, a company published a publicity article saying that the “milk exosome” it developed was officially approved to be included in the International Nomenclature of Cosmetic Ingredients (INCI) and obtained the ingredient submission code issued by NMPA, trying to prove that the safety, reliability and effectiveness of milk exosome have been recognized in China and abroad. 2

The publicity content shows that the company uses "ingredient submission code obtained" as a guarantee for the ingredient quality. This phenomenon is not an isolated case. Therefore, NIFDC issued an announcement emphasizing that the obtaining of the ingredient submission code does not mean the ingredient has been approved or recognized by the regulatory authorities. This announcement corrects some companies’ misconceptions about the submission code. Using “ingredient submission code obtained” for promotion will face the risk of being investigated and punished by the regulatory authorities.

ChemLinked expects to assist companies in applying for ingredient submission codes and registering/notifying cosmetics in China. If you have any further cosmetic compliance consultation needs, please contact us at cosmetic@chemlinked.com.

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