After 30 years, the National Medical Product Administration comprehensively revised the cosmetics regulatory system for the first time. It has released 8 new regulations, with 16 more to come in next year. It shows that China's supervision of the cosmetics industry is becoming more and more stringent, and practitioners must understand and abide by the law. Non-compliance will trigger serious legal consequences.
These 24 New Regulations Mainly Focus On:
Confirmation of alternative animal testing
Regulate on production safety and efficacy claims of cosmetics
Standardise the production process of cosmetics and ensure the product quality and safety
lor the first time, a comprehensive cosmetics management and the responsible person system have been established, with the corresponding level for safety risk management.
For the first time, the scope of responsibilities of cosmetics registrants and filing person is defined to ensure the safety of cosmetics.
Toothpaste products are now within the category of cosmetics.
How do they affect international beauty brands?
1. Increased the barrier for China market entrance
Brands must support product promotion and claimes scientifical basis. The basis can be related literature data, research data or efficacy evaluation data; a superficial claim of the ingredient is no longer sufficient and accepted.
The threshold for the china market investment will increase.
2. The previous entry methods (via Retailer/Trade Partner/Distributor) can no longer satisfy the long-term development in China.
Indie brands need to think more in-depth about the overall business strategies and models that will grow the brands in the long run.
3. Indie brands need to plan their brand position & strategy by genuinely understanding the Chinese consumers and market through pre-planned research:
Are you up for the BLUE or the RED sea?
Will they, the Chinese consumers, like the brand?
What is the purchasing attitude of Chinese consumers towards the brand?
4. The new management and responsible person system require brand owners to establish a more comprehensive presence in China.
Does your partner have the ability to follow up with the system requirement?
Are you going to entrust with Retailer/Trade Partner/Distributor, or will you have an entity set up for the operation?
The consequences for failing on the system requirements are severe. Brands will have the business suspended for at least 5-10 years with substantial penalty fines. Even if brands could resume the business, they will also face heavier censorship from the government regulatory body.
Reading More to know the Domestic Responsible
5. Stricker compliance and legal rules applied for the local business. The purpose is aiming to combat the grey market - illegal cross border business.
Appendix ：the 24 New Regulations System
Regulation on the Supervision and Administration of Cosmetics （2020.06 Released）
Registration Administration Method for Registration and Recordation of Cosmetics （2021.01 Released）
Standard Data Materials for the Administration of the Registration and Recordation of Cosmetics （2021.02 Released）
Standard Data Materials for the Administration of the Registration and Recordation of Cosmetics Raw Materials（2021.02 Released）
Cosmetics Classified Administration （2021.04 Released）
Guiding Principles for Classification of Non-special Cosmetics
Technical Guidelines for Cosmetic Safety Assessment （2021.04 Released）
Cosmetic Efficacy Claims 2021.04 Released
Measures for Supervision and Administration of Production
Practices of the Supervision and Administration of Cosmetics
Inspection specifications: Cosmetic Good Manufacturing Practices
Measures for the Administration of Sampling Inspections of Cosmetics Safety
The Norms for the Administration of Cosmetics Risk Monitoring and Control
Measures for the Monitoring of Adverse Cosmetics Reactions
Administrative Provisions on Cosmetic Supervision
Provisions on the Administration of Overseas Inspection of Cosmetics
Cosmetics Inspections Guide
Provisions on the Supplementary Testing Methods of Cosmetics
Measures for Supervision and Administration of Teeth-plate
Requirements on Data Materials for the Administration of the Registration and Recordation of Teeth-plate
Teeth-plate Classified Administration and Catalogue
The Catalogue of Raw Materials of Teeth-plate
Technical Guidelines for the Supervision and Administration of Teeth-plate
Measures for the Administration of Labelling
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