In China, a distinction is made between "special" and "general" cosmetics.
A Historical Breakthrough
After three decades of waiting, the Cosmetic Supervision and Administration Regulation (CSAR), the important overarching cosmetics regulation, came into force on January 1, 2021. During the transitional period, the applicants should continue to follow the existing regulations as long as the regulations supporting and interpreting the CSAR have not been released yet or only exist in draft form.
Since January 1, 2021, deodorants, hair growing, depilation, body slimming, and breast enhancement products, which used to be “special” cosmetics, cannot register with NMPA anymore. If products with these functions were registered prior to the introduction of the CSAR, they are granted a transition period of 5 years. During the transition period, production, import and sales can continue. After the transition period, they will not qualify as “special” cosmetics anymore.
From January 1, 2021 onwards, soaps with efficacy claims of “special” cosmetics are required to register as “special” cosmetics and obtain a registration certificate.
According to CSAR, toothpaste will need to be filed as “general” cosmetics in future.
The process of China NMPA filing ("general" cosmetics) and registration ("special" cosmetics) is demanding. Even large companies make mistakes. Cisema provides solutions customised for your products. Our experienced consultants guide you through the entire regulatory process in China until receipt of certificate, including identifying whether your cosmetics are "special" or "general", analysing the formula and packaging for China conformity, and preparing the application documents in Chinese. The NMPA certificate for "special" cosmetics is valid for 5 years, while the certificate for "general" cosmetics is valid indefinitely. Learn more about the process of China NMPA filing and registration including timelines in our brochures.
The DRA for cosmetics is responsible for the registration/filing, supervision of the tests, regulatory aspects during the application for approval, as well as partial responsibility for product safety and post-market surveillance.
Cosmetics manufacturers who intend to appoint a distributor as DRA should be aware of the related risks. Should your distributor refuses to hand over the original certificates to you or does not maintain your NMPA online account according to your wishes, you will unfortunately find yourself in a dependency, which can prevent you from changing the DRA, appointing new distributors, applying for change or renewal of your NMPA certificates and consequently importing your products.
You will learn about the responsibility scope and criteria for choosing the right DRA for your company in our brochures.
🞂 Are you a manufacturer and want to sell your cosmetics in China for the first time?
🞂 You may already sell your cosmetics in China online via CBEC but now wish to enter China via the general trade?
🞂 Are you unsure if your ingredients are China compliant?
🞂 Would you like to know how much time and costs you have to anticipate for the China NMPA registration or filing of your cosmetics?
🞂 Are you unsure who to appoint as your Domestic Responsible Agent (DRA)?
🞂 Wondering how many test samples you need to provide to Chinese laboratories?
🞂 Would you like to know if the packaging of the test samples must already look like the final product?
🞂 Do you have any concerns about revealing the exact manufacturing method and ingredients of your cosmetics as part of the registration?
🞂 You may already have certification for your cosmetics, but will it expire soon?
🞂 You don't know how a recently released regulation affects you?
🞂 Do you have a question regarding the QMS (quality management system) requirements in China?