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Proya: A Company Perspective on Ingredient Management under China's New Cosmetic Regulations

On Dec 8, 2020, speaking at the CRAC-HCF 2020 Virtual Forum by REACH24H, Mr. Ligang Jiang, the Chief R&D Officer from Proya Cosmetics Co., Ltd, analyzed how cosmetic enterprises should manage ingredients under the Cosmetic Supervision and Administration Regulation (CSAR) [1]. During the speech, Mr. Jiang summarized the key provisions related to ingredients in CSAR and its subsidiary regulations and their impact, hotly discussed issues in the industry, and his thoughts and recommendations on ingredient management from the enterprise perspective.

The following are some of the highlights of his speech.

NMPA Supervision Scope Extends to Ingredient Manufacturer – Introduction of Ingredient Submission Code

According to Mr. Jiang, a considerable improvement of the CSAR is that the NMPA has extended the supervision scope to the cosmetic ingredient manufacturers. Instructions for Cosmetic Registration and Notification Dossiers stipulated that when notifying or registering cosmetics, the ingredient sources, quality specifications, quality and safety documents, etc., should be submitted. But the ingredient quality and safety documents are so many that the uploading of each registrant and notifier will cause great waste of social resources.

To solve these problems, the NMPA came up with a method of ingredient submission code. Ingredient manufacturers are encouraged to submit ingredient quality and safety documents on the NMPA designated website. The ingredient submission code will be automatically generated after submission. The cosmetics registrants and notifiers can choose the ingredient submission codes when filling in the formula information during registration or notification.

The ingredient submission code brings considerable advantages. It will:

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