Filing Process to Replace Traditional Registration Procedures Filing Process Replaces Traditional Registration Procedures for Imported Non-Special Use Cosmetics

On September 27, 2018 The State Council has decided to substitute the registration method for imported non-special use cosmetics with cosmetic filing procedure as a part of the reform called “Separation of Certifications”. The new reform has been tested in Shanghai Pudong New Area since 2016/17.  Gradually it has been expanded to other Chinese pilot zones. The new reform is based on the very positive outcome from these pilot projects.

In essence, the objective of the new reform is to decentralize, ease market access, create a fair and transparent marketplace, and thereby stimulate economic growth. The new reform will restructure previous certification procedures and replace these with less bureaucratic processes. The reform, that forms the first step in a major decentralization reform, includes a total of 106 items of administrative examinations and approvals.

One of the many items to be reformed is registration of imported non-special use cosmetics, which will now be replaced with the cosmetic filing procedure method. Like the filing option in the pilot zones, the change centers on an amendment of the regulations of hygienic supervision of cosmetics.

The implications for foreign cosmetics companies are as follows;

1) Previously cosmetics filing could only take place in few designated pilot zones. The new reform intends to broaden the scope for cosmetic filing around China.

2) As cosmetics filing is quicker than cosmetic registration, the new reform will provide a swifter market access for foreign cosmetics brands. 

It is important to notice that animal test for filing of imported non-special use cosmetics is presently mandatory. Whether animal test will be abolished in the new reform is not mentioned in the present announcement.

Also note that the new reform does not yet include changes in the certification or registration processes of; functional health food, vitamins and minerals, or infant formula. 

Feel free to reach out to us, if you have any questions in this regard. We will keep everyone updated on these new changes as we get more information.

We wish to congratulate the Chinese government with the success of the pilot project and their continuous effort on easing market access and dismantling barriers for entry.