NMPA Unveils a Favourable Policy for Cosmetics

Ingredients information submission is an important part of the product registration record.

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On March 27, the National Medical Products Administration issued a "Notice on matters relating to the further optimization of safety information management measures for cosmetic ingredients (hereinafter referred to as Notice No. 34 of 2023)", which extended the reporting period for ingredient safety information to January 1, 2024. Previously, the policy stipulated that the deadline for former product ingredient information replenishment was May 1, 2023, which meant an additional eight-month buffer preparation period for companies.

According to the Cosmetic Supervision and Administration Regulation (CSAR) and other regulations and technical specifications, cosmetic registrants and filers should conduct safety risk assessments of cosmetic ingredients and fill in the information on the safety of ingredients used in product formulations during the registration and filing process.

As this is a new requirement in the CSAR, companies need time to adapt to the process and prepare information. Coupled with technical confidentiality concerns, ingredient suppliers are not very motivated to report ingredients. It has become a major constraint on cosmetic manufacturers, and brands' product registration for the record. Previously, many parties have called on the regulatory authorities to give clear guidance to have “soft-landing” for related practitioners.

It is understood that the new announcement is clear on two main points: First, the way to report, the registrant filer can fill in the reporting code. If there is no reporting code, the registrant can fill in the ingredients' safety-related information materials and upload the paper information stamped with the seal of the registrant, the filer scanned copies.

Secondly, a transitional period is delineated. From 1 January 2024, the registrant needs to fill in the raw material safety information for all the raw materials used in the product formulation.

The former product information filing was previously required to be completed before May 1, 2023. The new announcement extended to January 1, 2024, equivalent to an additional 8 months buffer period. As can be seen, the former product supplement is for specific ingredients, such as quality specifications required for ingredients, anti-corrosion, sun protection and other functional ingredients. Other ingredient information only needs to be ready to check, which will significantly reduce the time of enterprises to enhance efficiency.

Ingredients information submission is an important part of the product registration record. To a large extent, the efficiency of ingredients submission may also directly affect the efficiency of product filing.

Relevant personnel from a filing service agency also told CHAILEEDO, "There is more preparation time for new products, and many enterprises are happy to learn this news." Another person in charge of a filing consultancy from Guangzhou also said that the longer buffer period is beneficial to the efficiency of some enterprises.

In the opinion of Shen Yingjie, assistant general manager of COSMAX(China), the extension of the transition period is more significant for older products compared to that. He said that people are basically preparing the ingredients information for the new products first, "I think it is good for the former products because they are going to have problems if they are not made up again within the original time limit."

If the previous time limit is followed, the former product registrant filer should provide additional safety-related information on all ingredients in the product formula by May 1, 2023. If the filer doesn’t submit the information of ingredients in time, they will be written off. The product will not be able to continue to be produced and sold.

According to incomplete statistics from CHAILEEDO, about 270,000 cosmetic products were canceled last year in Guangdong, Hebei and Fujian. One of the most important reasons for this is that many companies had to choose to cancel their old product records because of the time-consuming and laborious nature of the information.

A number of industry insiders agree that companies have more time to prepare and former products are relatively easy to make up for the record, "More time means more a chance of survival." Shen Yingjie also said bluntly, "It is good for manufacturers and brands. After all, the workload is still quite a lot. But now there is sufficient time, so it is conducive to information perfection."