China requires companies to submit safety information on cosmetic ingredients in specified manner

On March 27, 2023, China’s National Medical Products Administration issued an announcement about the submission of safety information on cosmetic ingredients. This announcement requires companies to submit safety information on cosmetic ingredients used in their products in a specified manner in accordance with the Regulations on Cosmetics¹, Measures on Cosmetics Registration² and other relevant regulations.

Outline of the cosmetic ingredient safety information scheme

Cosmetic ingredient safety information is an important basis for product safety assessment. It includes information regarding quality standards for ingredients, the management of substances with safety risks, and ingredient safety risk assessment.

When registrants and notifiers of cosmetic products use ingredients listed in the List of Cosmetic Ingredients in Use³, they, as the entities responsible for the quality and safety of the products, must collect detailed information on the safety of the cosmetic ingredients in the products by requesting it from the ingredient manufacturers, referring to literature or conducting necessary tests, and prepare a document describing the cosmetic ingredient safety information.

Ingredient manufacturers must register cosmetic ingredient safety information in accordance with relevant regulations and standards, and are responsible for its accuracy and completeness. When cosmetic ingredient safety information is registered, a code associated with the registered information (“report code”) is automatically generated by the Cosmetic Ingredient Safety Information Registration Platform developed by the National Medical Products Administration.

Cosmetics registrants can use that code to associate cosmetic ingredients in their products with registered information when they register or notify the products. They don’t have to submit cosmetic ingredient safety information that has already been registered.

How to submit cosmetic ingredient safety information

After the above-mentioned announcement, cosmetics registrants can submit safety information on cosmetic ingredients used in their products as described below:

• If the ingredient manufacturers have registered the safety information of the ingredients on the Cosmetic Ingredient Safety Information Registration Platform and have obtained report codes, the cosmetics registrant or notifier only needs to provide these codes. The registrant or notifier has to obtain the safety information of the ingredients from the manufacturers.
• If the manufactures have not done the registration for the ingredients and have not obtained report codes, the registrant or notifier submits cosmetic ingredient safety information for the ingredients, and uploads required documents on the platform.
• If safety information is registered for only part of the ingredients of the cosmetic product, the registrant or notifier carries out both processes above.

The announcement of the National Medical Products Administration (in Chinese) is available at
https://www.nmpa.gov.cn/xxgk/ggtg/qtggtg/jmhzhptg/20230327145218196.html.

¹ 化妆品监督管理条例

² 化妆品注册备案管理办法

³ 已使用化妆品原料目录