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Interview Vol. 1 | Detailing Ingredient Submission Code Required for Cosmetic Registration and Notification

As per China’s new cosmetic regulations, cosmetic registrants and notifiers can fill in ingredient submission codes provided by their ingredient manufacturers to associate the ingredient safety information without the need to upload related documents by themselves. The ingredient submission code is totally a new notion. With an aim to help companies better understand it, ChemLinked asked Wennie Wei, the cosmetic regulatory specialist at REACH24H, to detailed explain this new notion and how companies should cope with it.
1. What is Ingredient Submission Code and its function?

The ingredient submission code is composed of a five-digit manufacturer digital code, a six-digit ingredient digital code, and a three-digit ingredient quality specification digital code. It is automatically generated after the cosmetic ingredient manufacturer submits the ingredient safety information through the online platform designated by NMPA. After submission, the ingredient submission code will be disclosed by the NMPA together with the ingredient trade name and manufacturer information.

With the submission code, cosmetic companies can directly associate ingredient safety information by filling it in when they submit applications of registration/notification online. Thus, they can save time for sorting and uploading ingredient-related documents by themselves.

From the perspective of supervision, the significance of the ingredient submission code is to extend the scope of supervision to all ingredients used in existing products or ingredients on the IECIC including both single substances and compounds, which will be convenient and effective for supervision departments to supervise the source of ingredients. If there is a problematic ingredient, the supervision departments can trace back from the system which formula is associated with the ingredient in a timely and direct manner, instead of letting the company report it after self-inspection.

2. Is it right that only the company manufacturing the ingredient can submit the ingredient safety information to obtain the code?
3. What's the difference between the ingredient submission code and new cosmetic ingredient notification/registration?
4. How should the ingredient safety information be submitted to obtain the code? What safety information needs to be submitted?
5. When can companies submit the information?
6. Could you give some suggestions on the ingredient submission code?

About the Expert:

Wennie Wei focuses on the research of Chinese and EU regulations and has extensive experience in cosmetic safety assessment. Currently, she is focusing on helping clients obtain pre-market approval for cosmetics and new ingredients in China. She has provided customized regulatory consulting services for several of the world's top cosmetic products and ingredient customers.

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