China Release Testing Report Requirement to Support Pudong Imported Non-special Cosmetics Filing Management System

Takehome:

• CFDA released instruction on how to generate testing report for Pudong filing management system, and guaranteed that finished testing report for registration can be used for filing management;
• Non-special use cosmetics of Shanghai local enterprises who entrust foreign manufacturers to complete the last procedure are designated as imported cosmetics, and can apply for import non-special use cosmetics filing certificate. Those enterprises don't require a "responsible person".

The testing institution should generate testing report in compliance with "Standard of Testing for Cosmetic Registration". For Pudong filing system, applicants should put the information of "responsible person" in the blank for "responsible agent", and meanwhile mark it as "responsible person" after "agent name".
 
If applicants have obtained testing report for registration and haven't submitted yet, they can choose to apply for Pudong filing certificate by using the same testing reports. Under this condition, if the former applicant (local responsible agent) is different from current applicant (responsible person), the current applicant should meanwhile provide evidence to prove it is the same product as the original tested one and an acknowledgement letter from former responsible agent agreeing to the use of the testing report.
 
In addition, according to "Provision for Processing Cosmetic Registration", when domestic enterprises entrust foreign manufactures to complete the last procedure (contacting inner content) of one product, this product is regarded as imported cosmetics. Extending to Pudong filing system, Shanghai local enterprises who entrust overseas company to manufacture their non-special use cosmetics, can apply for import non-special use filing certificate in Pudong. These local enterprises do not need a responsible person and are exempted from filling out information of "responsible person" in the system, but they should fully take the responsibility of product safety. They still should submit dossiers which required by "Provision for Processing Cosmetic Registration".