Takehome:
Shanghai FDA has outlined some problems in the implementation of the Pudong cosmetic filing management pilot program, specifically issues relating to responsible person requirements.
The main issue related to Responsible Person (for first import non-special use cosmetics) is that the address which was filled online is often different from the address used on-site. SHFDA regard it as the RP filling out false information, and the RP will be subject to certain punishment pursuant to relevant requirements in "Credibility Surveillance".
SHFDA also stated that they will use the experience garnered from the Pudong filing trial to develop a better system in preparation of offering the import non-special cosmetics filing management to other ports (Free Trade Zone).
For more information about pudong filing management practice experience, you may refer to Chemlinked Expert Article: Best Practice for Exporting Non-Special Cosmetics to China.


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