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CSAR Subsidiary Regulations: China to Implement the Strictest Cosmetic Sampling Testing Regulation

In September 2020 and June 2022, China National Medical Products Administration (NMPA) issued two drafts of Measures for the Management of Cosmetic Sampling Testing. Finally, on January 12, 2023, NMPA released the finalized Measures, which will be implemented on March 1, 2023. [1] The Measures is divided into 8 chapters and 61 articles, providing detailed requirements on the formulation of sampling testing work plan, sampling, testing and result submission, objection and re-testing, verification and disposal of unqualified products, as well as information disclosure. The key points are summarized and analyzed as follows.

Sampling Methods

To strengthen the supervision of cosmetic manufacture and operation in China, local medical products administration departments (MPAs) will organize the sampling testing according to their annual sampling testing plans.

Special personnel will be assigned to carry out the sampling through on-site sampling or online product sampling. Recognized testing institutions will be responsible for the sample testing.

  • During on-site sampling, the sampling personnel shall show the sampling work certification documents to the manufacturers and operators of the sampled cosmetics;

  • Online product sampling shall simulate the online shopping process, which means the sampling personnel shall not inform the manufacturers and operators of the purchase purpose.

With the development of e-commerce in recent years, online sales have become the main sales channel of cosmetics. It’s worth mentioning that the standardization of online product sampling requirements will be conducive to the development of the cosmetic industry. Unqualified products that are only sold online will have nowhere to escape under strict sampling testing requirements.

Sampling Procedures

The Measures makes detailed provisions on sampling procedures, as well as the rights and obligations of the competent authorities, testing institutions, manufacturers and operators, etc., during the sampling process. The whole process of sampling testing is shown in the figure below:

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