Shanghai MPA Official Details Cosmetic Filing Format/Compliance Review Key Points

On Nov. 7, during China's 2nd International Import Expo (CIIE), Liu Shu, Cosmetic Development Director at Center for Certification and Evaluation of Shanghai MPA outlined the differences in compliance review of imported non-special use cosmetics subject to filing under new regulatory requirements and cosmetics subject to registration under previous regulatory requirements...

On Nov. 7, Liu Shu, Cosmetic Development Director at Center for Certification and Evaluation of Shanghai MPA shared some knowledge relating to format review of imported non-special use cosmetics.

Ms. Liu first introduced the differences in format review scope between filing and registration, shown in the table below:

Content	Previous Registration	Filing
Are the documents standardized and complete?	In the review scope	In the review scope
Does the product fall under filing scope?	Not in the review scope	In the review scope
Are the e-documents clear? Are the paper version the same as the e-documents?	Not in the review scope	In the review scope
Do the prohibited/restricted ingredients in the formula comply with the corresponding requirements?	Not in the review scope	In the review scope
Do the product name and claim fulfil the requirements?	Not in the review scope	In the review scope

The Director went on to explain the rationale for adopting stricter requirements during format/compliance review is down to an attempt by government to protect the interests of consumers. Under the new system products which pass filing format/compliance review will be granted market access.

In addition, Ms. Liu highlighted 3 key points during format review of imported non-special use cosmetics subject to filing:

Key points	Details
Completeness of documents	Bar code: application form, technical specification and formula shall have complete bar codes Stamp: application documents shall include stamps of RP and formula shall include the stamp of testing institution Product name: formula explanation, related commitments and instructions shall include product names Documents of explanation Documents of translation Signature and date Form: fill out completely Notarial certificate
Standardization of documents	Provide valid signature and date Include valid and clear stamps Fill out standardized name, e.g. ingredient name Provide clear documents and copies Use compliant claims
Consistence of documents	Bar code is same in different documents Scan copies are the same with electronic version The product name in the application form is the same as other documents The translation is faithful to the original version Overlap information in all documents are the same