China NMPA Relaxes the Threshold for the Person in Charge of Cosmetic Quality and Safety

Background

China's new cosmetic regulation, the Cosmetic Supervision and Administration Regulation (CSAR), has added mandatory staffing requirements for cosmetic registrants, notifiers, and entrusted production enterprises. They should be equipped with “a person in charge of quality and safety" ("the person"), who shall have professional knowledge related to the quality and safety of cosmetics and more than five years of work experience in cosmetic production or quality and safety management, to undertake corresponding product quality and safety management and product release responsibilities.

Relaxed Threshold

The high qualification requirements for the person make the cosmetic industry face the tough talent gap. Given this situation, China National Medical Products Administration (NMPA) relaxed the qualification requirements for the person in its reply letter about the person on April 27, 2022. ¹ Details are as follows:

• Since the principles of production, as well as quality and safety management of health-related products such as drugs, medical devices, and special foods, are basically the same as those of cosmetics, the person's experience in the production and quality management of drugs, medical devices, and special food can be regarded as the experience in the production and quality and safety management of cosmetics, under the premise of having professional knowledge related to cosmetic quality and safety.

• The medical products administration departments shall strengthen the supervision, inspection, training, and guidance for the person of cosmetic registrants, notifiers, and entrusted production enterprises within their respective administrative regions, assess whether the person has professional knowledge and performance capabilities related to cosmetic quality and safety, and urge them to fulfill corresponding product quality and safety management and product release duties in accordance with the law to ensure product quality and safety.

Industry Comments

• The first point of NMPA’s reply means that the qualification requirements for the person in charge of quality and safety are no longer strictly limited to those with experience in cosmetic production or quality and safety management. Cosmetic enterprises can introduce qualified personnel from related industries, which can help relieve the current talent shortage to a certain extent.

  However, it should be noted that the premise of hiring the person with production or quality and safety management experience from related industries is to have professional knowledge about cosmetic quality and safety. Thus, it can be seen that NMPA does not lower the requirements and standards for the person but provides a buffer policy for the smooth transition of the new cosmetic regulations.

• Regarding the second point of NMPA’s reply, some industry experts believe that this is a strong signal that in the future, the person in charge of quality and safety may need to receive formal occupational training and examinations and obtain a corresponding certificate before taking their posts.