CSAR China cosmetics regulations are being increasingly enforced by the NMPA (National Medical Products Administration). This is leading to the increased identification of infringements of the CSAR (Cosmetics Supervision and Administration Regulations) as witnessed recently with the suspension of production of lavender essential oil by the manufacturer Jian Shan Lake.
On April 15, 2022, China’s NMPA announced on behalf of the Anhui Medical Products Administration (MPA) that it is suspending Jian Shan Lake’s production of lavender essential oil (No.1-3-2022).
The reason for the suspension is that the essential oil contains 2.5% “vanilla butyl ether” in its product formula which exceeds the 1.5% allowed according to the IECIC (Existing Cosmetic Ingredients in China) 2021. Exceeding 1.5% is considered harmful to human health as well as imposing safety risks.
Suspending production can be enforced under the CSAR when production can cause human injury or cause potential health risks. This is specified in Article 54 of the Cosmetics Supervision and Administration Regulations, namely:
“all business operations and production related to the cosmetics product, either causing human injury or with evidence indicating potential health risks on human beings, can be suspended immediately by the responsible department under the NMPA”.
CSAR China cosmetics infringements – How to avoid
Observing CSAR requirements for product formulas is vital to avoid suspension of the production, marketing, or sale of cosmetics in China. Applicants should ensure the content of raw materials used in cosmetics comply with the Chinese regulations as the product formula is a key component of the filing and registration of a cosmetic product in China.
In cases of suspension, the manufacturer can apply to the relevant MPA or the NMPA for administrative reconsideration within 60 days. Another option is to file an administrative lawsuit with the local court within 6 months.
At Cisema, we can assist you with ensuring that your company meets the latest product quality and safety requirements in China. We act as an NMPA Domestic Responsible Agent for cosmetics manufacturers and cosmetic ingredient suppliers worldwide.
Cisema covers all your needs from registration to post-market compliance to in-China OEM and subsidiary localization.
Send us your enquiry to see how we can help you.
By Jeff Jiang.