Filing of Imported Non-Special Use Cosmetics with Beijing MPA

On 20.01.2020, the Beijing MPA (Medical Products Administration) announced (No.6-2020) a list of administrative measures for the filing process of imported non-special use cosmetics as below:

– If the Domestic Responsible Person is located within the administrative area of Beijing, the filing of imported non-special use cosmetics should be submitted to the Beijing MPA. In the past, if the Domestic Responsible Person was located within the administrative area of Beijing, the applicant had the free choice between provincial Beijing MPA and the NMPA (National Medical Products Administration).

– Before importing the products for the first time, the Domestic Responsible Person must utilize the NMPA online account for the filing. To do so, he/she must log in to www.nmpa.gov.cn to register the account name, upload the product filing information, and submit the paper version to the Beijing Government Affairs Service Center in person to obtain the electronic filing certificate.

– If the Domestic Responsible Person relocates from Beijing to a different province in China, he/she has the responsibility to update this information in the NMPA online account.

– The Domestic Responsible Person shall commit to establish a quality and safety management system with the foreign manufacturer, strengthen product traceability, bear product quality and safety responsibilities, ensure that the imported cosmetic products and operations meet the requirements of regulations and standards, as well as inform the public in a timely manner for product recalls if any adverse events were to happen.

– All MPA departments shall conscientiously exercise their supervision functions on the Domestic Responsible Person and the imported cosmetics products, strengthen the coordination and cooperation with relevant departments such as customs, provide timely reports on the product quality and safety information, and investigate illegal acts with the relevant departments.

Since 10.11.2018, the product registration process of non-special use cosmetics in China has been replaced by a new filing method that requires the assistance of a Domestic Responsible Person.

The filing location heavily depends on the place of registration of the Domestic Responsible Person. Currently, there are 14 municipalities with the capacity to file non-special purpose cosmetics: Tianjin, Liaoning, Shanghai, Zhejiang, Fujian, Henan, Hubei, Guangdong, Chongqing, Sichuan, Shaanxi, Hainan, Shandong, Beijing. If the Domestic Responsible Person is registered in one of these 14 provinces, the imported non-special cosmetics require filing with that respective provincial counterparts of the NMPA.

Since the announcement on 20.01.2020, the NMPA only handles the filing of exceptional cases. For instance, if the Domestic Responsible Person is not located in any of the 14 municipalities, the filing is required to be approved by the NMPA. All special purpose cosmetics continue to be filed with the NMPA.

Cisema has a team of experienced consultants to guide you through the regulatory process of China NMPA registration of special cosmetic and MPA filing of non-special cosmetic products, which includes communication, notary fees, collection of registration file, Domestic Responsible Person application, review of formula + Chinese name + packaging, translations, test sample import and transport, tests, compilation of registration dossier, reply to the supplementary notice and certificate provision. Feel free to contact us if you would like to know more about our full scope of services.