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Takehome:
- To record cosmetics online before selling will be mandatory when the new "Statute for Control of Cosmetic Hygiene" is officially published (See news on: CL). Here Chemlinked offers an exclusive Q&A and will offer guidance on the most frequently asked questions.
- Enterprises will be required to fill out 6 items: products basic information, responsible person, related manufacturer, product package information and record statement.
On product basic information:
Q: For "foreign name" of the product, can I enter another language apart from English? What if the product doesn't have a foreign name?
A: The "foreign name" could be in another language, but it's better to use English. Currently the blank of "foreign name" is mandatory; product without foreign name should put "NA" or type Chinese name again into this blank.
Q: What does "series of product" mean in "product type" item?
A: "Series of product" here means cosmetics in the same series, they share same formula, same form and functions, and only differ in colorants or perfumes, e.g. the same series of lipsticks has different colors.
Q: There is no option of "mask" to select in "product type", how can I fill out the blank of "product type"?
A: There is no option of "mask" category to select, because "mask" is not a category in Taiwanese cosmetic classification. The "mask" will be supplemented to classifications in the new "Statute" in the future. Currently, enterprises of "mask" product can choose "lotion" similar to "essence" products, because normally masks contain essence to protect skin.
Q: Can a travel package be recorded as one product on the system?
A: No, travel package cannot be regarded as one product. Any single product in the package, such as shampoo, shower gel and face wash should be recorded online individually. Additionally, any products sold in packages (e.g. mask and lotion) should be recorded individually.
On responsible person and related manufacturer
Q: If the set information about responsible person or manufacture is wrong on the system, what should I do?
A: The set information is automatically updated from the database of Ministry of Economic Affair. If the information is wrong, it is recommended to tap new information into the system first, and then go to windows of Ministry of Economic Affair to update the information.
Q: If my product has more than one authorized manufacturer, are all manufacturers required to record?
A: Yes, all manufacturing plants are required to be recorded.
On "shared ingredients" and "all ingredients"
Q: Why do I get a pop up of "shared ingredients" when recording certain products?
A: If the recorded product is "series of product", then blank of "shared ingredients" will pop up, and enterprises should fill out the same ingredients shared by one series.
Q: What's the difference between "functional ingredients" and "other ingredients" in "types of ingredients" item?
A: If the ingredient is listed in "Maximum Levels of Medical, Poisonous or Potent Drugs in Cosmetics" and "Standard for Usage and Maximum Concentration of Permitted Preservatives in Cosmetic" or is restricted by TFDA announcement, then this ingredient belongs to "functional ingredients". Ingredients not in the above groups are "other ingredients". If the ingredient belongs to "functional", it should select "standard concentration" and fill out the exact concentration used in the product. While for "other ingredients", it can select "proper concentration" without filling out the exact concentration used.
Q: What if the function of certain ingredients in Taiwan are defined differently from the country of origin, how to fill out the blank of "function"?
A: It is suggested to fill out original definition of function.
Q: Should I put all ingredients in order of concentration?
A: There is no special requirement on putting ingredients in order.
On packaging
Q: If one product has different sizes of packages, does it require individual recording of each package?
A: One product with different packages can be recorded in one time. As long as add "new package" item in the "package" column.
General problems:
Q: Will all recorded information about a product be disclosed to consumers or the public?
A: Currently, recorded information is not disclosed to the public and is only used for reference by TFDA. Enterprises should fill out information honestly, because the information will be disclosed partially to the public in the future without revealing confidential business information.
Q: How to modify the information in case of any change?
A: If enterprises want to modify their information, they enter "case withdraw and repeal" page from the main menu, and click modifying items and select "repeal by self" to delete these items. Then enterprises should re-apply and fill out these deleted ones.
Q: If overseas enterprises want to import cosmetics to Taiwan, can they apply for an account?
A: Currently, this system is only applicable to domestic manufacturer and authorized agent; overseas enterprises cannot record their products by themselves.
Q: If the products of one enterprise are numerous, can all of them be recorded? Does the system have a maximum limit?
A: Currently there is no maximum limit for the system, so all cosmetic products from one enterprise should file a record.
Q: Does toothpaste require a record?
A: Only toothpaste with whitening functional ingredients (Hydrogen Perxidel1.5%-6.0%) requires recording, other toothpastes don't belong to cosmetic category and don't require it.
Q: After finishing the record, should enterprises check every now and then if their products are approved?
A: After finishing the record, if the recorded product doesn't contain new ingredients, the system will issue approval automatically. But if the product contains new ingredients or ingredients that the system can't recognize, the case will be shifted to manual review, and then enterprise should check how the case is processed by clicking "inquiry" in the system.
These tips may help you operate the record system and sell cosmetics in the Taiwan market. Currently the cosmetic online record system is free, however when it becomes mandatory after the new "Statute" published, fee may be charged. It is recommended to record now if you want to tap your cosmetics into Taiwan market. Chemlinked.com will continuingly follow any change for this policy and update it to you.
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