I want to sell my cosmetic product in China but, what should I do?

CSAR – Cosmetics Supervision and Administration Regulations 

The State Council of China published the final version of CSAR on June 29th, 2020. This regulation came into force on January 1st, 2021, and replaced the existing Cosmetic Hygiene Supervision Regulation (CHSR). 

CSAR aims to ensure the quality and safety of cosmetics by strengthening the supervision and management of cosmetics and the control of production and operations to protect consumer health. 

Changes in regulation 

China’s new cosmetics regulation discusses many changes. But some key updates include: 

  • New cosmetic definitions, scope, and classifications. 
  • Management of new cosmetic ingredients. 
  • Safety assessments for cosmetic products and requirements for safety assessors. 

New cosmetic definitions, scope, and classifications 

Cosmetics are defined as daily chemical products intended to be applied to the external part of the huma body (such as skin, hair, nails, lips, etc.) by spreading, spraying, or other similar ways for cleaning purposes, protection, beautification, or grooming. 

Therefore, products applied to the teeth or oral mucosa or to the external genitalia are not considered cosmetics, unlike our European legislation. 

In addition, a distinction is made between two types of cosmetics: special and general cosmetics. 

Among the special cosmetics, we can find the following categories: hair dyes, hair permanent products, freckle removal products (whitening), sunscreens, hair loss products and cosmetics with new effectiveness. 

And, speaking of general cosmetics, it can be said that they are all those products that meet the definition of cosmetic and have not been classified within the classes of special cosmetics. 

One of the main differences between both types of cosmetics is the difficulty in marketing them in China: 

  • Special cosmetics: They still require REGISTRATION of the product through the NMPA with a validity of 5 years. 
  • General cosmetics: They no longer need registration, but a NOTIFICATION is made that will be permanent. Only the presentation of an annual report with the information of the products notified in that year being necessary. 

Management of new cosmetic ingredients 

It is managed in a similar way to finished cosmetic products. By this, we mean that they are also differentiated into two categories: 

  • New high-risk cosmetic ingredients: They need a REGISTRATION process. They are preservatives, UV filters, colorants, hair dyes, bleaching agents, or freckle removal. 
  • New low-risk cosmetic ingredients: By means of NOTIFICATION, valid for any new ingredient that is not included in any of the previous categories. 

Safety assessments for cosmetic products and requirements for safety assessors 

Since the implementation of CSAR, the security evaluation by the company responsible for the product is mandatory. This safety assessment is made base don: 

  • Ingredients: Include abstract, physicochemical properties, analysis of the evaluation result, risk analysis, signatures, CV of the evaluators, references, and appendices. 
  • Finished cosmetic product: It must be based on all the ingredients and the possible interactions between them, in addition to all the safety studies. 

In this area, the figure of the Safety Evaluator comes into play, who must be properly trained and qualified for it, in addition to having at least 5 years of experience in the field of safety evaluation of cosmetic products. 

Don’t forget, as always, that from Sigillum KS we can help you with this whole landing process in the Chinese market. Contact us!