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Laure Moutier Intertek
Welcome to our new Assurance in Action podcast series dedicated to China Cosmetics Market. A new Chinese cosmetic regulation called Cosmetics Supervision and Administration Regulation came into force on January 1st 2021, replacing the existing Cosmetics Hygiene Supervision Regulations. In this podcast series, we will discuss the requirements introduced by this new regulation, the key changes and updates to cosmetics regulation in China.
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Laure Moutier Intertek
I am Laure MOUTIER from Intertek France and I am with my colleague Celeste TENG from Intertek China who will answer some questions about the new Chinese regulation
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Celeste Teng Intertek
Hi everyone.
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Laure Moutier Intertek
So let's begin this podcast series with the subject of cosmetic ingredients in China. Which ingredients can be considered as new or existing ingredients. How do we check their compliance for the Chinese market and what are the requirements for each raw material that is used in cosmetic products? Celeste will help us understand what our obligations are if we intend to commercialize a cosmetic, raw material or cosmetic product in China.
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Laure Moutier Intertek
To begin, let’s say I’m a raw material manufacturer and one of my clients would like to commercialize their cosmetic product containing my raw material in China. How do I know if my raw material is authorized in China?
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Celeste Teng Intertek
Well, China has a list called IECIC which is short for Inventory of Existing Cosmetic Ingredients in China. The latest version is the 2021 version that has been implemented since May 1st 2021. For an ingredient to be used in a cosmetic product in China, it is necessary to ensure that the ingredient is listed in this inventory. If not, it will be considered as a NEW cosmetic ingredient and it will have to be either notified or registered.
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Laure Moutier Intertek
And how do we notify or register a new cosmetic ingredient in China?
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Celeste Teng Intertek
If the new ingredient is a preservative, a UV filter, a colorant, a hair dye, a spot removing or a whitening agent, it will be considered as “high risk” in China and will have to be registered. That means it has to be approved by the Chinese authority before being allowed on the market. Any other types of ingredients can be notified, meaning an approval is not needed pre-market.
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Laure Moutier Intertek
And what exactly is the difference between a registration and a notification?
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Celeste Teng Intertek
The main difference is that registration requires approval and notification does not. In case of registration, when we submit the dossier to the authority, it will go into a review process, both administrative and technical. The review committee might have questions or comments regarding this ingredient. These need to be addressed before they make a decision. So there could be some back-and-forth communications. All these steps would make the registration process quite lengthy. It can take several months or even more before we actually get the approval. On the other hand, in the case of notification, when we submit the dossier to the authority, within 5 working days they will publish a notice about our case and at which point we can consider the notification has completed.
03:57 --> 04:38
Celeste Teng Intertek
Other than that, there isn’t much difference. In both cases, the dossier requirements are the same. The applicants of both notification and registration will have to submit an annual report to the authority on the sales and safety monitoring of their ingredient for 3 years starting from the day the ingredient starts to be used in China.
After these 3 years, if the ingredient is considered as safe: it will be added to the IECIC. And if it is not considered safe, then the notification will be cancelled or the registration will be retracted.
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Laure Moutier Intertek
If the ingredient is listed in the inventory IECIC 2021, can I consider it as compliant for the Chinese market or should I check other lists and regulations?
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Celeste Teng Intertek
Yes Indeed, other than the IECIC, we should also make sure the ingredient complies with the Safety and Technical Standards for Cosmetics, we call it STSC version 2015. In the STSC, there are several lists. Two lists contain the prohibited substances. Another one contains restrictive substances, meaning substances can only be used under certain conditions. Then there are 4 positive lists which contain preservatives, UV filters, colorants and hair dye agents. If for example an ingredient’s main function is preservative, then this preservative must be included in the positive list of preservatives. If it is not listed there, then this ingredient cannot be used as a preservative in a cosmetic product in China.
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Celeste Teng Intertek
We also need to make sure that the ingredient’s concentration does not exceed the maximum percentage of use currently known in leave on and rinse off cosmetic products in China which is also an information of the IECIC 2021. If the concentration exceeds this maximum limit, we will need to submit further proof regarding the ingredient’s safety.
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Celeste Teng Intertek
Please also note too that if the ingredient enters China as a raw material directly instead of being in a cosmetic formula product, we should also check for compliance with the IECSC, which is the Inventory of Existing Chemical Substances, under the Ministry of Ecology and Environment.
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Laure Moutier Intertek
And once I ensure that the ingredient is compliant with IECIC and STSC, is there any further step to take before it can be commercialized in China ?
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Celeste Teng Intertek
The next step will be to submit the safety data of cosmetic raw materials in order to obtain a submission code to be given to downstream clients. Actually, the online platform for data submission has been operational since December 31st 2021 so a lot of companies are starting to perform the submission now.
Up to this day, there are over 7000 raw materials for which safety data have been already submitted.
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Laure Moutier Intertek
How does it work ? Who is in charge of submitting the raw material safety data on this platform?
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Celeste Teng Intertek
Both cases are possible. The submission can be done by raw material manufacturers themselves, or it can be done by another party on their behalf if the raw material supplier authorizes it.
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Laure Moutier Intertek
Does this safety data submission pertains to all raw materials that are used in China?
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Celeste Teng Intertek
Yes. This pertains to all materials, but there are different transition periods for different types of raw materials. If this is a preservative, UV filter colorant, hair dye, or spot removing or whitening agents. What we called « high risk ». Then the complete set of safety data will need to be submitted starting from January the 1st, 2022.
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Celeste Teng Intertek
And if the ingredient has another function, it will be considered as medium or low risk and the complete set of data will be required starting only from next year January 1st 2023. And before this date, only some basic data will be required, such as the trade name, the information about the applicant company, etc.
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Laure Moutier Intertek
And what happens if I do not submit the data and obtain the submission code in time?
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Celeste Teng Intertek
Well, without the required submission data for raw material, it won't be allowed in the cosmetic products in China and that unfortunately means your downstream customer clients will not be able to successfully notified or register their products and therefore won't be able to sell their products in China.
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Laure Moutier Intertek
So thank you very much, Celeste for your detailed answers.
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Celeste Teng Intertek
My pleasure, Laure.
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Laure Moutier Intertek
That concludes today's podcast. For your information, Intertek can support you in the notification or registration of new cosmetic ingredients in China or in the submission of raw material safety data. We can also help you to identify what your obligations are, whether you are a raw material manufacturer or a finished cosmetic products manufacturer.
Join us again in a later podcast where we will discuss the commercialization of finished cosmetic products on the Chinese market. Notification and registration process, labeling, claims, tests and more. Thank you for listening and see you soon.
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Celeste Teng Intertek
See you bye
