The issuance of Decree No 638 by the state council on July 27th has caused considerable confusion as to whether or not imported cosmetic products are still subject to label review by CIQs. Decree No 638 effectively abolished the article 34 of Decree No.477, which stated that “before import and export of food and cosmetics, CIQs will review the label and issue a certificate for label review”.
An official at the CIQ informed Chemlinked that CIQs will continue to conduct label review on imported cosmetic products at ports but the label preview prior to importation and the issuance of certain certification were abolished.
The label preview of cosmetic products was almost fully cancelled as far back as 2006 according to AQSIQ Announcement 44. Another change to labeling of cosmetics is that according to AQSIQ Announcement 39 imported cosmetic products that pass the CIQ inspection need not bear CIQ marks since 1 Feb 2012.
It is worth clarifying that the obligations of label preview and CIQ mark were mandatory under the previous “Measures for the Administration of Imported and Exported Cosmetics Supervision and Inspection” (AQSIQ Order 21 of 2000). It was then replaced by the Measures for the Administration of Imported and Exported Cosmetics Inspection and Quarantine Supervision (AQSIQ Order 143 of 2011). Under the new rules, all these previously mandatory requirements have been abolished except for the on-site label review at ports.
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