On the 18th of July, the State Council issued its Decree No. 638 regarding the Determination of Abolishing and Modifying Part of Administrative Laws and Regulations which includes one of the provisions that labeling review for imported/exported cosmetics was deleted.
However, now regulatory affairs expert April Guo tells CosmeticsDesign-Asia.com that this refers to the labeling pre-review and that so far, the cancellation of labeling review referred by Decree No. 638 is limited to the cancellation of compliance preview of the labeling of imported/exported cosmetics.
Which essentially means that CIQ will still be reviewing imported cosmetics; “Given that CIQ’s order 143 issued in 2011 is still effective, it will still be checking at different ports if labels of imported cosmetics meet China’s requirements.”
Cosmetic labelling requirements have changed however..
Earlier in the year the Bureau had announced that cosmetic companies were no longer required to obtain a China Inspection and Quarantine label for imported cosmetics, providing those products have passed the bureau’s inspections.
The older version required imported cosmetics to pass the inspection of the AQSIQ while also being affixed with a CIQ label as without it the product was not allowed onto the Chinese market.
Then, Guo had told this publication that; "It is easy to buy fake CIQ labels and put them on imported cosmetics, the goal of using CIQ labels to protect consumers can easily be undermined" and that "importers need to submit a declaration to CIQ that the cosmetics will not be used for trade purposes and record the flow of those cosmetics."
Although the aforementioned labels will no longer be required for imported cosmetics, the government body says companies will still need to provide documentation when applying for an inspection on the Chinese market.
Amongst requested paperwork, industry professionals must provide a self-declaration letter stating that the imported cosmetic product complies with relevant Chinese laws and the normal use of the product will not cause any harm to human health, the product’s formula and a hygiene license or record-keeping certificate.