The cosmetics market in China has experienced exponential growth, solidifying its position as one of the largest markets globally. With an estimated value exceeding 516 billion Yuan in 2023, the industry continues to expand at a rapid pace, fueled by rising disposable incomes, urbanization, and shifting consumer preferences.
Skincare products dominate the market, accounting for the largest share of sales, followed closely by makeup and hair care products. E-commerce platforms have played a significant role in driving sales, with online channels accounting for a substantial portion of total cosmetics sales in China.
The market is characterized by fierce competition, with both domestic and international brands vying for market share. Key players in the industry include multinational giants such as L'Oréal, Estée Lauder, and Procter & Gamble, as well as local champions like Pechoin, JALA, and Chando.
China NMPA Cosmetic Regulations
“Cosmetic products refer to daily chemical products intended to be applied on the external part of the human body (such as skin, hair, nails, lips, etc.) by spreading, spraying, or other similar ways for cleansing, protecting, beautifying, or grooming purposes.” The term "any" external portion and the function "eliminate unpleasant odour" have been eliminated from the prior definition.
Classification of Cosmetics as per China NMPA Cosmetic Regulations
Special Cosmetics | General Cosmetics |
| This includes-skin care, hair care, nailcare products, makeup and perfumes, etc. There is a five-year grace period for the following categories: Hair growth cosmetics, hair removing products, breast slimming products and deodorants registered as special use cosmetics before july 1, 2021.after the transition period, production, import and sale these products will be prohibited. |
Chinese Regulatory Authorities
The regulation of cosmetics in China is overseen by the National Medical Products Administration (NMPA), formerly known as the China Food and Drug Administration (CFDA). The regulatory framework for cosmetics is primarily governed by the Regulations Concerning the Hygiene Supervision of Cosmetics and the Administrative Measures for the Hygiene Supervision of Cosmetics.
The new china cosmetic regulation, the Cosmetic Supervision and Administration Regulation (CSAR) - - Aims to improve cosmetics quality and safety by increasing cosmetics supervision and management, as well as controlling production and operations to protect consumer health.
SAMR is the State Administration for Market Regulation, which is in charge of overseeing the markets for food, cosmetics, medicines, and medical equipment.
Cosmetic ingredients will be regulated by the National Medical Products Administration (NMPA) depending on their dangers. New preservatives, sunscreens, colourants, hair dyes, and whitening agents, for example, must register with the NMPA and gain approval, whereas low-risk compounds merely require notification.
IECIC is an objective and thorough database of ingredients found in Chinese cosmetics that have been created and sold. It is the only source of information on the regulatory status of cosmetic ingredients.
Regulatory Framework In China
The Ministry of health has approved a new regulation for cosmetics that released from JAN,1 2021 Cosmetics Supervision and Administration Regulations (CSAR), which was previously held by Cosmetics Hygiene Supervision Regulations, released in 1989. The CSAR in China will release administrative rules to establish China’s Cosmetic Regulatory Framework. According to the new rules in China, cosmetics now are defined as Special Cosmetics and General Cosmetics. Special Cosmetics are required to be registered with the NMPA and the registration certificates are only valid for five (5) years, on the other hand ‘General cosmetics’ are required to filing and these certificates do not any expiry dates. For the domestic cosmetic products manufacturing in China- The applicant should provide product test and research data carried out for the Chinese market.
New Cosmetic Ingredients (NCI)
According to Article 11 of the CSAR the cosmetic ingredients are categorized as-
New ingredients- It is a natural or artificial ingredient which possess high risk that is applied in cosmetic products for the first time in China. The NMPA must authorize it before it may be used in cosmetics. After three (3) years of registration or filing, new ingredients must submit annual safety reports, and any subsequent new ingredient must undergo a safety assessment test conducted by professionals with more than five (5) years of expertise. Any cosmetic claim must be backed up by scientific evidence, which may be found on the NMPA website.
Existing ingredients- All the other ingredients which are available in IECIC are the existing ingredients which should just be filed with the NMPA.
SAMR
Main responsibilities include:
Market management
Market entity registration
Quality and safety supervision
Standardization work
Market Authorization Process (NMPA)
Filing Person and Registrants Qualifications
Has Cosmetic Quality Management System
Has Responsible Person In Charge Of Cosmetic Quality And Safety
Has An Adverse Reaction Monitoring And Evaluation System
Person Should Have Atleast 5 Years Of Experience In Cosmetic Regulation
Chinese Responsible Person
The responsible person for the product's quality, safety, and efficacy is the applicant for cosmetic product registration or filing. (Article 6.) A product safety evaluation must be performed by the Responsible Person or a professional institution prior to the registration or filing of a cosmetic product. Persons with knowledge in cosmetics quality and safety, as well as five years of relevant work experience, must conduct the safety evaluation. (Article 21.) A Responsible Person can either make the goods themselves or entrust it to other manufacturers. (Article 28.)
Domestic Notification / Registration of Cosmetics
Special cosmetics must register with the NMPA under China's new cosmetic regulations, but regular cosmetics just require a brief notification.
Classification | Pre-Market Obligation | Competent Authority | Certificate | Post-Market Obligations |
Special Cosmetics | Registration | NMPA | Registration License | Registration Renewal |
General Cosmetics | Notification | NMPA or Local Provincial MPA | e-Certificate (Payment) | Annual Report Submission |
Application Process
Involved Entities
Registrant/Notifier: The first person accountable for cosmetic safety, and he has the option of producing cosmetics himself or entrusting the production of cosmetics to other businesses. The registrant or notifier is responsible for the entire product life cycle, from development to production to distribution.
Responsible person (RP): overseas cosmetics registrants and notifiers must designate a domestic responsible person who will handle cosmetic registration and notification, assist them in cosmetic adverse reaction monitoring and product recalls, and cooperate with the medical products administration department's supervision and inspection.
Cosmetic registrants/notifiers entrust entrusted production enterprises to create cosmetics for them. The entrusted production firm must meet all applicable production requirements, organize production in accordance with applicable laws, rules, and contractual agreements, be accountable for production operations, and accept supervision by cosmetics registrants and notifiers.
2. Duration and Cost
The duration and cost of the entire registration and notification process are determined by the cosmetic product's category and properties. In general, regular cosmetics take 3-6 months to be notified, whereas special cosmetics can take up to ten months to be registered. Sunscreen, freckle removal and whitening, anti-hair loss, and other products take longer to develop since additional efficacy testing are required.
The testing charge, efficacy evaluation test fee, translation fee, notary fee, and consulting fee are all included in the registration or notification cost (if a regulatory consultant is involved). Registration and notification are both free of charge at the NMPA.
3. Dossiers Necessary for Notification/Registration
Type | Required Dossier |
User Permissions and Account Application (Step 2) |
|
Notification and Registration application (Step 4) |
|
4. Safety Assessment
Technical Guidelines for cosmetic safety assessment
A subsidiary measure of CSAR + a replacement to guideline for cosmetic safety risk assessment
Qualification of Safety Assessor
CSAR - Article 21
Personnel engaged in safety assessment shall possess professional knowledge related to cosmetic quality and safety
Shall have 5 years of relevant professional work experience.
Draft guideline- Article 3
Shall possess knowledge in areas such as medicine, pharmacy, chemistry, toxicology.
Well understand the requirement of manufacturing process and the control of safety and quality of cosmetic product
Shall have more than 5 years of relevant work experience
5. Efficacy Claim Evaluation
The efficacy claims of cosmetics must be supported by sufficient scientific basis, which includes literature articles, research data, or efficacy evaluation test findings, according to the Standards for Cosmetic Efficacy Claim Evaluation (“Evaluation Standards”) (including human trial, laboratory test and consumer use test).
Beginning January 1, 2022, cosmetic registrants and notifiers must complete the efficacy evaluation themselves or entrust it to an evaluation institution with the necessary capabilities, and disclose the efficacy evaluation abstract on the NMPA-designated special website for public viewing at the time of registration and notification.
It's worth noting that the evaluation abstracts for the following two sorts of efficacies can be withheld.
Efficacy claims that can be recognized directly by vision, smell, and other senses, such as cleansing, makeup removal, beautifying and embellishing, perfuming, body refreshing, hair dying, hair perming, hair colour maintenance, depilating, deodorizing, auxiliary shaving and barbering, and so on.
Efficacy claims that work by just covering, preserving, or frictioning the skin, and are expressly stated on the label to have solely physical effects, such as freckle removal and whitening by physical covering, physical exfoliating, physical elimination of blackheads, and so on.
Imported Cosmetic Registration, Filing Procedure and Dossier Checklist-NMPA
Filing Procedure For Imported General Cosmetics-
Filing Procedure For Imported Special Cosmetics-
Cosmetic Labelling Requirement-NMPA
Name of the product (in line with Requirements on Naming of Cosmetics)
Manufacturer's name and address, as well as distributor's name and address
Originating country
Approval ID number (such as "J20130000") on administrative license or record-filing certificate
Ingredient list (all substances with concentrations more than 1.0 percent must be mentioned in decreasing order of "quantity" with Chinese INCI names; in the lack of an INCI name, the corresponding name in the Chinese Pharmacopoeia, its chemical or botanical name can also be used)
Content on the internet
The batch number and expiration date, or the production date and shelf life
Warnings (for products containing banned substances, such as Zinc phenolsulfonate, the term "avoid contact with eyes" must be included on the label; and for special-purpose cosmetics, such as hair dye)
Condition of instruction and storage (provided if inadequate storage impacts safety)
Additional information (the local distributor or wholesaler can be indicated as well)
Labeling cosmetic products for import into China now has two options:
Companies may create a label tailored to the Chinese market based on the above description.
Companies may create a China-recognized over-label to affix to imported products sold within the country.
While the CSAR has been praised by many in the personal care, beauty, and cosmetics industry for opening up many new opportunities for selling these products in what may soon be the world's largest market, these new labelling provisions are bolstered by a framework for levying fairly significant penalties and fines against companies that fail to comply.
Animal Testing-NMPA
Animal Testing Exemption for General Cosmetics
According to the Provisions for Management of Cosmetic Registration and Notification Dossiers, China officially removed the mandatory animal testing on MAY 1, 2021, for general cosmetics, whether it is imported or manufactured in China. Cruelty-free brands from other countries can now enter Chinese cosmetic market without animal testing but it must meet the two preconditions and three exceptions given below-
Two Preconditions | Three Exceptions |
| Animal testing is not permitted for the following three cosmetic categories: • Cosmetics for infants and children • Cosmetics that use novel substances throughout their three-year monitoring term • Cosmetics whose notifier/RP/manufacturer is identified by the NMPA as a major supervision target |
Animal Testing Requirements for New Cosmetics
Data from the Animal testing alternative methods (not included in China’s STSC but validated by an international authoritative alternative method validation agency such as OECD, ICCR, ICCVAM, EURL-ECVAM, JaCVAM, etc.) for NCI registration and notification can be conditionally accepted and are used for toxicological tests for NCI, Evidence demonstrating that the approach can anticipate the toxicological endpoint properly should be submitted. In addition, appropriate Integrated Approaches to Testing and Assessment (IATA) should be selected during the evaluation of NCI safety based on the structural properties of the component and specific toxicological endpoints.
Animal Testing Exemption Conditions (According to ZMUni)
General cosmetics only
QMS certification issued by local government
Not intended for infants or children
Does not use new ingredients that are in the safety monitoring period
The filing person, Chinese responsible person, or manufacturers do not have bad records in China.
Children Cosmetics-NMPA
The ‘Draft Regulation on Supervision of Children's Cosmetics,' published by the National Medical Goods Administration (NMPA), comprises labelling standards and production rules for cosmetic products for children under the age of 12.
The following are important aspects to remember from the regulation:
For the sake of children's safety, raw materials such as fragrances, colorants, harsh preservatives, and surfactants should be used less frequently, and gentle ingredients should be used instead;
Raw materials that have been used safely in the past should be chosen, and materials that are still in the monitoring period should not be used;
Acne, hair removal, hair strengthening, deodorization, scar removal, anti-dandruff, hair coloring, and perming are all examples of raw components that should not be utilized in children's cosmetics.
Artixio provides cosmetic registration services in China using its local presence. For any queries regarding cosmetic regulations in China, please email us at info@artixio.com
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