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According to the notice released by CFDA for public comments on 5 Nov, China will adopt EU cosmetics management mode to regulate the domestic Non-Special Use Cosmetic Products (Non-SUCPs), indicating that China will partially modernize its cosmetic regulatory framework.
It is well-known that under EU new cosmetic regulation EC 1223/2009, cosmetic manufacturers could notify their products through an online notification portal and should keep a product information file (PIF) for future reference, which includes description of the product and production process, product safety report, proof of the effect claimed, animal testing data, etc.
To follow a similar pattern, from 1 Jun 2014, according to the new Rules for Information Filing of Domestic Non-SUCPs, applicants of domestic Non-SUCPs are no longer required to obtain the record-filing certificate but just notify to provincial FDAs the product formula and sale packaging (including labels and instructions for use) through an online notification portal prior to marketing. After local FDAs check the completeness and authenticity of information, CFDA will release those notified products on their website which are searchable by the public.
In the meantime, the cosmetic manufacturers based in China should keep a record of the following information for post-market examination:
- a product safety evaluation report
- description of production techniques
- list of production facilities
- product technical requirements
- testing reports
According to the above-mentioned new Rules, toxicological tests will be an optional requirement for Non-SUCPs manufactured in China. Cosmetic enterprises are allowed to prepare safety assessment materials to demonstrate product safety without carrying out animal testing but using existing animal testing data or EU validated non-animal testing data. The move is conducive to alleviating many of the issues caused by the different animal testing policies in China and EU and opens the door for foreign cosmetic companies that adhere to “cruelty-free” status, such as The Body Shop, LUSH and Urban Decay, to enter Chinese market.
Hilary Jones, the Ethics Director of LUSH Cosmetics made the response that there is a strong demand for cruelty free cosmetics amongst Chinese people. They know it because they serve so many Chinese holiday makers in LUSH’s London shops. It is fantastic that the Chinese government understands these desires. The new policy changeover could pave the way for cruelty free brands to trade in China and make it possible for Chinese brands to sell into Europe. Lush applauds the big move and looks forward to a cruelty free China.
“Those large cosmetic companies that stick to non-animal testing can set up factories in China just like L’oreal and Mary Kay so that they can continue the way they take in Europe and evade the animal testing issue; for those small overseas cosmetic companies, the feasible way could be to export cosmetic in bulk and have them sub-packaged for retail in China”, recommended by Mr. Martin Hu, the cosmetic regulatory affairs expert from REACH24H Consulting Group.
The policy shift is also extremely welcomed by Humane Society International (HSI), the NGO leading the world’s largest “Cruelty Free Campaign” to promote beauty without animal suffering (see ChemLinked news on 18 Jul). In light of revision of China’s top cosmetics regulation, HSI has taken the key change to propose removal of mandatory animal testing to CFDA (see ChemLinked news on 10 Oct). Upon receiving this news, Troy Seidle, the HSI’s Director of Research and Toxicology, shared with ChemLinked reporter the great influence and meaning to be brought about by it. “Ending mandatory animal testing for cosmetics and wholesale regulatory acceptance of non-animal testing methods validated in the EU are two major asks of HSI’ cruelty free china campaign. It is exciting to see the Chinese regulator has taken them up so swiftly. Although this will initially apply only to Non-SUCPs manufactured within China, companies throughout the world will no doubt applaud this move and look forward to its extension to cover all cosmetic products, including imports”. He said.
Mr. Troy also mentioned the new policy will for the first time make it possible for companies in China to manufacture cosmetic without animal testing, which will inspire companies to create innovative cruelty free products so Chinese consumers will have the same choices as their counterparts in the West. Ultimately, however, the impact of this policy could be far-reaching. Countries with substantial exports to China that have been reluctant to ban animal testing of cosmetics on the grounds of not disadvantaging their own domestic industry may now look at the issue with fresh eyes. And companies that say they only animal test when it’s legally required may soon have one less legal requirement to hide behind. Taken together, the new Chinese animal testing policy not only marks a major milestone in HSI’s Be Cruelty-Free campaign but also is one of the turning points in the process of ending cosmetics animal testing worldwide.
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