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The Future of Cosmetics in China: Why Animal Testing Will End Sooner Than People Think

  •   5 Dec 2018
  •    Paul O Brien
  •  118
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    I am expecting China to change its animal testing requirements for imported cosmetics in the short term (maybe we will even see a change in upcoming technical standards and postive inventory system - IECIC) . I think China will utilise a system whereby high risk products/ingredients will still require animal testing data and lower risk products will either be exempt from testing requirements or eligible to generate safety data (toxicological etc.) through the use of alternative models or computer based quantitative risk assessment.

    While animal testing of cosmetics gets all the attention, animal testing is also heavily utilized in other sectors. Use of risk stratification to determine regulatory compliance obligations represents a broader regulatory trend in China which has already been rolled out in China's pesticide sector (significant reduction in animal testing requirements) and I expect will also be implemented in its health food sector going foward (also likely to mean reduction in animal testing).

    In line with this seachange China has been developing facilitated market entry pathways for imported cosmetics like "special filing" and CBEC which are based on this post-market assessment and surveillence principle and also industry self regulation. This new facilitated market entry principle is best exemplified in China's "special" filing system for first imported general cosmetics (non special cosmetics without functional claims) which was initially implemented as a pilot program in Pudong but has recently been expanded nationwide. The system allows a greatly expedited route to market using a special type of filing (not the same as filing of domestically manufactured cosmetics). Sure animal testing data is still required for now but reading between the lines of administrative reform and regulatory trends ive a feeling its not long before all of that changes.

    China has already realized a second phase of sweeping insitutional reforms replacing the former CFDA with the SAMR and setting up China's first department specifically for administrating cosmetics in China, namely China's Cosmetic Safety Supervision Deparment under the Natioanl Medical Products Administration (subdepartment of SAMR). As mentioned above part of its broad mandate of the SAMR and NMPA's Cosmetic Safety Supervision Department is a shift towards post-market assessment, classified management of cosmetics and optimization of technical standards to align with global best practices.

    New optimized oversight mechanisms are being developed such as a more efficient feedback loop between market authorities (SAMR) and customs authorities (GAC) to calibrate premarket inspections based on post market violations (China's enterprise credit rating system) and optimize post-market rectifications such as recalls based on testing at ports. Additionally we can expect digitization of administrative processes which will further facilitate this feedback loop likely leveraging supply chain digitization, traceability etc.

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