Decentralized registration on imported cosmetics in China may be inconsistent

Earlier this month, the State Commission Office for Public Sector Reform (SCPSR) made the registration process easier for the cosmetics industry​ in that it developed a new organisation structure of the reformed FDA authority in China.

Previously there were complaints from foreign cosmetic companies and industrial associations about the Chinese government’s differential treatment towards imported and domestically-made non-SUCs.

Caution​

Although a step forward, Martin Hu, cosmetics regulatory expert from REACH24H points out that the detailed guidance on the registration of imported non-special use cosmetic products is yet to be released so it remains unknown whether the pre-market application will still be required.

The regulatory expert also states that the overseas manufacturers may be faced with inconsistent approval and supervision requirements carried out by different food and drug administrations at provincial level.

Improvement​

There is no denial of the improvements made however, as Hu explains that even for the same kind of products, imported ones are subject to post-market registration with CFDA while domestic ones only need to obtain a record-filing certificate from the provincial FDA within two months after cosmetic products are placed on the market.

This means that the new structure put in place will, to a certain extent, ease the dissatisfaction from these firms and will shorten the registration duration.

The new structure will also mean that CFDA experts can be more concentrated on the review of special use cosmetics and new cosmetic ingredients for more efficient and transparent registration procedures.

Provincial level​

As part of the new structure, the manufacturers of imported non-special use cosmetics are no longer required to register their products with CFDA but only with the food and drug administrations at the provincial level; similar to that of domestic non-special use cosmetics.

CFDA also takes over the responsibility of manufacturing licensing of cosmetic products and compulsory inspection from AQSIQ, which will only affect domestic production enterprises of cosmetics since overseas manufacturers are not subject to this system.