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Interview Vol. 3 | China Cosmetic Animal Testing Exemption: What’s the Impact? Any Possibility for Post-market Animal Testing?

In the past, China required all imported cosmetics to conduct animal testing, which prevented many overseas companies from entering China through general trade. Eventually on May 1, 2021, China exempted mandatory animal testing for imported general cosmetics. This is definitely a great news for overseas companies, but there are also certain thresholds. ChemLinked invited Joanna, the senior regulatory consultant from REACH24H, to talk about the thresholds and impact of animal testing exemption in China.
1. What are the preconditions for cosmetic animal testing exemption in China?

There are three conditions for animal testing exemption.

  • First, your product must be general cosmetics. Special cosmetics like sunscreens, whitening cosmetics are still required to be animal tested.

  • Second, you should provide a certificate of compliance to the good manufacturing practices (GMP) issued by the competent authority of the country of origin.

  • Third, the safety assessment results can fully confirm product safety.

What may be a little tricky is the GMP certificate issued by the government. For some regions where GMP certificates are generally issued by associations or third-party organizations, their governments are considering introducing solutions to help local manufacturers obtain the certificates.

I suggest stakeholders ensure their certificates can reflect the government’s actual supervision of the entire manufacturing process and quality control system. What’s more, the local manufacturing standards must be equal to or higher than the international GMP standards.

2. Are there any exceptions for cosmetic animal testing exemption in China?
3. The animal testing exemption is an established direction. What impact will it bring to oversea companies?
4. For general cosmetics without a recognized GMP certificate, and special cosmetics, how to exempt animal testing?
5. The animal testing exemption that we have been discussing is all about pre-market testing. How about post-market testing? Is it still possible to conduct animal testing for products sitting on store shelves?

About the Expert:


Joanna Ru

Senior Cosmetic Regulatory Consultant at REACH24H

Joanna has a master’s degree in Chemical Engineering from the University of Ottawa and more than 3 years of experience supporting major cosmetic companies’ regulatory compliance efforts. She mainly focuses on researching Chinese cosmetic regulations, including the finished cosmetic products and new cosmetic ingredients, has assisted loads of clients to obtain pre-market approvals and complete import filing for their cosmetic products, such as La Prairie, REVLON and EOS. Also, she was invited to give presentations on various events and platforms, such as ICMAD, Cosmetic Compliance, as well as ChemLinked. In addition, she is sophisticated in global cosmetic regulations, including ASEAN, Korea and Japan, which provides a professional regulatory information for various cosmetic companies. Joanna’ s global regulatory expertise and strong business acumen afford her a strategic vision to navigate the regulatory and compliance challenges that often accompany new technologies and growth into new markets.

Previous Interview:

Interview Vol. 2 | Sharing Key Points of NMPA Internal Training on China Cosmetic Registration and Notification Regulations

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

CSAR Exclusive Interview: Animal Testing, New Ingredients and What Next? (Full Transcript)

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