CRAC Special Report: Further Reform of China’s Cosmetic Regulations on the Cards

The last two years have seen numerous changes in China’s cosmetic regulatory framework and administration system, from promulgation of overarching regulation right down to refinements in technical standards. Despite the scale of reform reaching an unprecedented level during this period, the coming years, as suggested in a speech at CRAC by Mr. Liu Yang—chief of cosmetic department of China Flavor and Fragrance Cosmetic Industry Association, will be sure to see further reforms and upheaval.

The upward growth pattern spanning the last ten years shows a strong correlation between regulatory reform and market development. The most significant areas in reform work can be categorized into 3 key areas:

1. Cosmetic Ingredient List

The first prominent change happened in mid-2014 when CFDA released the list of existing cosmetic ingredients (IECIC), allowing industry to verify the existing ingredients used in cosmetics and to standardize the management of new cosmetic ingredients in China. However, the CFDA has not conducted any risk assessment of the ingredients listed in the IECIC, leaving manufacturers the responsibility to individually conduct risk assessment in order to ensure ingredient safety. This is far less of a challenge for international companies than it is for domestic ones, noted Liu, due to disparities in the technical capacities of Chinese companies versus their international counterparts. Liu revealed a second round of adjustment to cosmetic ingredient list might come soon, which is expected to see the addition, revision and deletion of numerous ingredients with specific attention being directed at botanical ingredients. China’s future modification of the cosmetic ingredient list will be based upon a principle which is often referred to as “mobile adjustment”, which involves looking at real time industry data and the takes into consideration the status quo of the industry rather than attempting any cookie cutter reformations.  This new strategy is a major breakthrough in policy-making which signifies the government’s further alignment with realistic market dynamics.

2. Cosmetic Labeling

The draft Administrative Measures on Cosmetics Labeling released for public comment last November by CFDA remains under discussion. Previously scheduled for implemented in July 2015, it seems 2016 may be a more feasible estimation. The delay is thought to be caused by opposition from international companies against the stipulation that increases the requirements and stringency of labeling terminology. As the principal system to examine cosmetic labels, the measure, if passed, will surely place pressure on international players within the Chinese market regarding the redesign of original labels in Chinese language and in line with Chinese standards.

3. Cosmetic Inspection and Supervision

Cosmetic inspection administration in China has long been hindered by redundancy and overlap of regulatory responsibility between China’s authorities. The refinement of the manufacturing permit system in 2013 to a “one certificate one manufacturer” system is a good sign. Another improvement that can be expected in the near future is the rebuilding of inspection forces, involving the training and introduction of fresh blood with proper knowledge of cosmetic production, ingredient hazards, adverse effects and risk assessment to carry out corresponding inspection and supervision work. The shift from “pre-market permit” to “post-market monitoring” will set the tone for the coming years’ reform, added Liu, which is inevitable as China continues to open its door to the whole world.