China NMPA Pilots Cosmetics Personalized Services in Five Provinces and Cities: An Upcoming Era of Cosmetics Personalization

The pilot project aims to explore feasible models and effective regulatory measures for cosmetics personalized services, to form replicable experiences and practices, and to promote the high-quality development of Chinese cosmetics brands and the industry.

General Requirements

The pilot project is organized by NMPA, and implemented by Beijing, Shanghai, Zhejiang, Shandong, and Guangdong medical products administration (MPA) departments. NMPA will evaluate the effect, and determine whether to extend the pilot time, expand the pilot scope, and increase the variety of pilot products. For the pilot model with good effect, NMPA will summarize its experience and promote it.

The MPAs of these five provinces (cities) shall submit the implementation plans for pilot project and other relevant documents to NMPA before December 1, 2022. The implementation plans shall meet the following requirements:

1) The pilot project shall not violate Cosmetic Supervision and Administration Regulation and its subsidiary regulations, and shall be implemented within the scope of NMPA’s authority;

2) The pilot object of personalized service shall be general cosmetics, excluding special cosmetics, children's cosmetics and cosmetics with new ingredients that are still in the monitoring period;

3) The pilot project should meet consumption needs of the public and have social promotion value.

Key Pilot Work

The pilot project shall focus on the following aspects:

Explore personalized service models. Encourage enterprises participating in the pilot project (hereinafter referred to as “pilot enterprises”) to focus on 1) general cosmetics such as makeup and skin care product, as well as 2) areas such as skin testing, product tracking, and personalized skin care;
Explore effective regulatory measures for the personalized service models. The MPAs of the five provinces (cities) are encouraged to innovate the supervision mode under the current cosmetic regulatory framework, and optimize the supervision methods in terms of product notification, testing, sample retention, and sales management;
Research and formulate normative documents related to personalized services. Through the pilot project, under the premise of compliance with regulatory requirements on notification, production supervision and risk monitoring, the personalized services can be optimized to not only ensure the quality and safety of cosmetics, but also meet the individual needs of consumers.

Selection Criteria for Pilot Enterprises

The MPAs of the five provinces (cities) will select 1-3 registrants or notifiers with strong production and R&D capabilities, comprehensive production quality management systems, and good reputation as pilot enterprises. The specific selection criteria are as follows:

above designated size and with good reputation;
have independent production and strong R&D capabilities;
have a comprehensive production quality management system;
have comprehensive product traceability and after-sales service capabilities;
no non-compliant products have been found in the supervision and inspection in the past three years;
no administrative penalties from the local MPA in the past three years.

It can be seen from the above selection criteria that NMPA has set a very strict threshold for pilot enterprises.

Steps to Participate in the Pilot Project

Step 1: Cosmetics registrants and notifiers in Beijing, Shanghai, Zhejiang, Shandong, and Guangdong submit an implementation proposal for cosmetic personalized service to the local MPA.

Information Required in the Implementation Plan

1) Basic information about the enterprise;

2) Pilot mode and implementation method;

3) Compliance analysis of the pilot mode and the implementation method;

4) Quality and safety control measures for pilot products;

5) After-sales service;

6) Value analysis of the pilot model;

7) Other contents related to the pilot project.

Step 2: The local MPA organizes and evaluates whether the implementation proposal meets the requirements of the pilot project and regulation, whether it can ensure product quality, whether it is operable, and whether the enterprise is capable of carrying out the pilot project.

Step 3: After the local MPA approves the proposal and submits it to NMPA for filing, the pilot enterprise can provide personalized services accordingly. If NMPA finds problems in the implementation process, it will require the local MPA to adjust or correct it timely, otherwise, the pilot project shall be suspended.

Industry Comments

"Personalized Beauty" has gradually emerged in the global cosmetics market and is welcomed by Chinese consumers for its brand-new model and format. At the 5^th China International Import Expo held in November, personalized beauty became a consumption trend targeted by international cosmetic giants. However, previously, cosmetic regulations did not clearly define personalized cosmetics or set up specific regulations. Although cosmetics regulations did not ban personalized cosmetics, many practical difficulties have led to the slow development of China's personalized cosmetics industry.

On August 1, 2022, Several Provisions on the Innovative Development of Cosmetics Industry in Shanghai Pudong New Area came into force. It took the lead in encouraging enterprises to accurately develop general cosmetics that meet the individual needs of consumers, and allowing notifiers in Shanghai to set up business premises in Pudong New Area to provide personalized service.

Three months later, NMPA released the announcement on the pilot project, which can be regarded as a positive signal to encourage enterprises to develop personalized cosmetics. An industry insider believes, "With the release of this announcement, I think there will not be too many obstacles at the policy level for personalized cosmetics. Besides, other related policies are expected to be released later." ²

On the other hand, from the selection criteria of pilot enterprises, most small and medium-sized enterprises do not meet the requirements for participating in the pilot project. At present, China’s personalized cosmetics are still dominated by leading cosmetics enterprises.

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 [email protected].