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

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.

No, in China the cosmetic ingredient manufacturer is defined as the enterprise responsible for the safety of ingredients. It can be the actual production enterprise of ingredients, the affiliated enterprise belonging to the same group company as the actual production enterprise of ingredients, or the entrusted enterprise engaged in the entrusted production of ingredients.

International or domestic ingredient manufacturers can submit cosmetic ingredient safety information by themselves, and they can also authorize other international or domestic legal entities to submit and maintain the information, such as their ingredient distributors, or third-party compliance companies like my company REACH24H.

New cosmetic ingredient notification/registration targets cosmetic ingredients that are not listed on the IECIC and used for the first time in China. The object is a single substance, which can be understood as an INCI name. The new cosmetic ingredients can be used in cosmetics only after registration/notification. While the ingredient submission code is for the existing cosmetic ingredients that are listed on the IECIC, including both single substances and compounds in the form of mixtures.

The cosmetic ingredient manufacturer shall submit the Enterprise Information Form and the certification documents of the enterprise entity through the ingredient safety information service platform of the NMPA to enable the submitting permission. After that, they can submit the ingredient safety information.

The ingredient safety information includes the ingredient trade name, the ingredient basic information, the brief descriptions of ingredient production processes, necessary quality control requirements, assessment conclusions of international authoritative institutions, limit requirements for risk substances, etc.

The system of submitting the information is not yet launched, and we need to wait for further notice from NMPA. 

However, China has formulated relevant transitional measures and set corresponding point-in-time. You can refer to it and make corresponding preparations in advance. 

To give ingredient manufacturers enough time to submit the ingredient safety information in advance, NMPA regulates that cosmetics registrants/notifiers need to fill in the source of product ingredients and trade name information only when registering/notifying cosmetics starting from May 1, 2021. 

Starting from 2022, ingredients with special cosmetic efficacy require submission of ingredient safety information. 

Starting from 2023, the requirements for the submission of ingredient safety information will be fully implemented. Cosmetics already registered or notified requires supplementation of ingredient safety information before May 1, 2023.

For the intelligent supervision of ingredients in the future, NMPA may vigorously promote ingredient submission codes. For the sake of convenience and safety, cosmetics finished products companies may give preference to ingredients with the submission code. Therefore, this is an advantage and opportunity for ingredient manufacturers with ingredient submission codes. It is recommended that ingredient manufacturers follow the new regulations to sort out existing ingredient safety information as soon as possible and submit it in a timely manner after the system is online.

For cosmetic finished products companies, it is recommended to sort out the information of ingredients used in the registered/notified products based on the ingredient suppliers and ingredient trade names and record the information of ingredients to be used in new products in advance in accordance with the transitional measures mentioned above. In addition, they can inform or promote their ingredient suppliers to submit ingredient safety information timely and obtain the submission codes. Thus, they can save time to prepare the ingredient documents on their own and their applications for registration/notification will not be slowed down.