Q&A of CIRS Webinar in December Regarding the New Regulations of Cosmetics and Cosmetic Ingredients in China

In the middle of December in 2021, Personal and Home Care Division of CIRS Group China held free webinars on the following two topics in Chinese, English, Japanese and Korean.

• The Latest Regulatory Requirements for Cosmetics in China and the Opportunities and Challenges for Companies
• The Latest Regulatory Requirements for Cosmetic Ingredients in China under the Supervision of NMPA and the Opportunities and Challenges for Companies

More than 400 people participated in each topic. We sorted out the questions with top concern to share.

Q1. How to choose the use part as the classification code when the product is applied on legs and/ or arms?

CIRS: According to Cosmetic Classification Rules and Classification Catalogue, the code 03 trunk and 08 hands/feet are available for products applied on limbs. If products are clearly not used for hands and feet, only the trunk can be selected. In addition, it should be noted that deodorant products can’t be applied to the hands and feet.

Q2. What materials should be provided for the registration/filing of cosmetics produced in Hong Kong, Macao and Taiwan?

CIRS: According to the Measures for the Administration of Cosmetic Registration and Filing, it is regarded as import products manufactured in Taiwan, Hong Kong and Macao. There are detailed dossier requirements for the registration and filing of cosmetics in the Provisions on the Administration of Cosmetics Registration and Filing Data. The registration or filing number of cosmetics from Taiwan, Hong Kong and Macao are different from other imported products, and the number consists of 国妆网备制字 (abbreviation of the province, autonomous region or municipality directly under the Central Government where the domestic responsible person is located) plus four-digit year number and sequence number of national filing products in the current year.

Q3. How to renew the registration license of original special use cosmetics?

CIRS: Where the registration licenses of original special use cosmetics need to be extended upon expiration of the validity period, the cosmetics registrant shall conduct a self-examination and evaluation of the products 6 months prior to expiration of the validity period of the registration certificate. The original online application system for cosmetics administrative license has been closed, and the registrant or the domestic responsible person shall apply for the license renewal of special cosmetics through the cosmetics registration information service platform within the prescribed time limit in accordance with the Measures for the Administration of Cosmetics Registration and Filing.

Q4. How to fill in the formula info of products containing propellant?

CIRS: According to the Measures for the Administration of Cosmetic Registration and Filing, in case the propellant is in contact with the contents of the product directly, the type and amount of the propellant should be indicated in the column of remark of the formula.

Q5. For imported cosmetics, must the Chinese labeling info be consistent with that of the original package?

CIRS: It is necessary to distinguish between the Chinese label and label sample. The content of the label sample should be consistent with the original package. The specific format refers to Appendix 17 Product Label Sample in Provisions on the Administration of Cosmetics Registration and Filing Data. The contents of Chinese label should comply with the provisions of Article 7 of Administrative Measures on Cosmetics Labels.

Q6. Both CI77891 and Titanium Dioxide are listed in IECIC, is there a distinction between them on the usage?

CIRS: Titanium Dioxide is commonly used in cosmetics as a sunscreen agent, colorant, filler, and opacification agent. According to the Provisions on the Administration of Cosmetics Registration and Filing Data, for the use of colorants, the colorant index number ( short for CI number) specified in the Safety and Technical Standards for Cosmetics should be marked in the column of ingredient name of the product formula unless there is no CI number. When titanium dioxide is used as a colorant, it is recommended to use the index number CI 77891 directly or to mark the index number beside the ingredient name. In addition, for nano-titanium dioxide, nanoscale needs to be marked beside the name.

Q7. How to determine type of notification (registration or filing) for new cosmetics raw materials with multiple purposes?

CIRS: For new raw materials with multiple functions for notification, as long as one of the functions belongs to the scenario for registration, the new raw materials should be registered in accordance with the Measures for the Administration of New Cosmetic Ingredients Registration and Filing Data; If the multiple functions do not belong to the scenario for registration, it can be filed with the NMPA. Registrants and filers of new cosmetics raw materials cannot conceal the actual functions of new cosmetics raw materials intentionally. The function of registered or filed new raw material should be consistent with its function used in cosmetics.

Q8. What chemical name should be used for the registration or filing of new plant extract?

CIRS: Generally, the standard name of the plant raw materials is given in terms of the properties of extracted target and obtained products. If it is a crude extract, it is usually named as “xxx extract”. If a certain group of active ingredients with a clear chemical structure can be obtained or enriched, it can be named in the form of total component. For a highly purified monomeric compound, it can be named by this compound substance. The chemical name can refer to Standard Chinese Name of International Cosmetic Ingredient List if the raw materials are included in the list. Nevertheless, for other raw materials not included in abovementioned list, the standard Chinese names are formulated combining with the common naming principles and the Chinese Pharmacopoeia and other authoritative inventories.

Please click the following links to watch the video replays of the webinars:

The Latest Regulatory Requirements for Cosmetics in China and the Opportunities and Challenges for Companies

The Latest Regulatory Requirements for Cosmetic Ingredients in China under the Supervision of NMPA and the Opportunities and Challenges for Companies

If you have any needs or questions, please contact us at service@cirs-group.com.