Tmall Global Adds New Management Requirements for Imported Cosmetics Containing CBD

On March 22, Tmall Global, the top cross-border e-commerce (CBEC) platform in China, announced to update the Tmall Global Cosmetics Platform Standard with the addition of new management requirements of imported CBD cosmetics. The revised standard will take effect on April 6, 2021. ¹

Tmall Global Cosmetics Platform Standard stipulates the basic cosmetic terms, cosmetic product posting specifications, cosmetic labeling information, claim specifications, product quality specifications, merchant specifications, and platform punishments.

Details of the updates to the standard are as follows (new requirements are highlighted in red):

Before Revisions

After Revisions

4.1.4 Specification for the release of product attributes:

When releasing products, the brand name, product specifications, product names, country of origin, cosmetic shelf life, expiration date, net content, application methods, warnings, etc., must be correctly marked. The attributes of the products filled in the attribute column must be true and meet relevant standards of the original country/region of sale.

Note: Please remember to mark the shelf life and production date of the cosmetics.

4.1.4 Specification for the release of product attributes:

When releasing products, the brand name, product specifications, product names, country of origin, cosmetic shelf life, expiration date, net content, application methods, warnings, whether it contains CBD (cannabidiol), etc., must be correctly marked. The attributes of the products filled in the attribute column must be true and meet relevant standards of the original country/region of sale.

Note 1: Please remember to mark the shelf life and production date of the cosmetics.

Note 2: When "Yes" is selected for the option " whether it contains CBD (cannabidiol)," a THC testing report of the corresponding product shall be uploaded, and the THC content shall not exceed 0.3%.

ChemLinked Comments

Chinese government holds a very cautious and even strict attitude to cannabis products, especially considering China has some of the harshest narcotic control laws. Cannabis ingredients are subject to strict supervision by the anti-narcotics department of the public security bureau. By far, only three cannabis-related ingredients are allowed to be used in cosmetics, including cannabis Sativa fruit, cannabis Sativa seed oil, and cannabis Sativa leaf extract.

So, strictly speaking, CBD is not included in the Inventory of Existing Cosmetic Ingredients in China 2015 (IECIC 2015) as a permitted single component ingredient, although it is one of the most studied and headlining grabbing components of the cannabis Sativa leaf extract. Thus, the use of CBD in cosmetics is illegal. CBD products imported via general trade are likely to be rejected during customs inspections and almost non-existent in the market. The notice of China NIFDC on March 26 also undergirds this point. In the future, the use of CBD in cosmetics may be subject to strict prohibition in China. ²

Given the risk and cost of the general trade, many niche international CBD brands choose CBEC to enter China’s market. The introduction of the new management requirements for imported cosmetics containing CBD by Tmall Global will help fill the regulatory gap, ensure product safety, and standardize the market.

*ChemLinked also provides services to help brands enter Tmall Global. If you have any further questions, please feel free to contact us at [email protected].