Published on 6 December 2022


China State Council released the final version of CSAR (Regulations on the Supervision and Administration of Cosmetics) on 29th June 2020. This regulation came into force on 1st January 2021 and replaced the existing Cosmetics Hygiene Supervision Regulations, which was first released in 1989.

CSAR aims to ensure the quality and safety of cosmetics through strengthening the supervision and management of cosmetics and controlling the production and operations to protect consumer health.
Some important changes with deadlines scheduled in 2023 are described below.

 

REGULATION CHANGES

China’s new cosmetics regulation addresses compliance requirements, and many of the key changes and updates are as follows:

 

  • New cosmetic definitions, scope and classifications

CSAR defines cosmetics as ‘’ daily chemical products intended to be applied on human skin, hair, nails, lips, mouth, etc., by spreading, spraying or other similar ways for cleansing, protecting, beautifying, or grooming purposes’’.

Toothpaste is not considered a cosmetic product, and a notification must be completed before entering the market.

Soaps remain outside of the scope of CSAR; the only exceptions are soaps with special cosmetic efficacies.

The classification of “special cosmetic products” (cosmetics with special purpose or function) has been updated to include hair dyeing, hair perming, spot removing and whitening, anti-hair loss, and any new function as determined by the National Medical Products Administration (NMPA).

Other cosmetic products fall under general cosmetics.

 

  • Cosmetic efficacy claims

Cosmetic claims must be substantiated by sufficient scientific evidence, and the applicant is to make this information publicly available on the NMPA’s website. Claims may be substantiated by literature, research data, or product efficacy evaluation data.

 

  • Safety Assessment of cosmetic Products

For registering or filing of cosmetic products, as well as new cosmetics ingredients, it is necessary to conduct a safety assessment.

General cosmetics can be exempted from animal testing if the safety and quality requirements (GMP/ISO issued by government) is met/proven.

 

  • Safety Information of cosmetic Ingredients, including Fragrance

For raw materials functioning as preservatives, sunscreen agents, colorants, hair dyes, dark spot-removing agents, and whitening agents, the safety data shall be submitted and is mandatory from 1st January 2022.
For other raw materials, including fragrance, the safety data shall be submitted and is mandatory from 1st January 2023. Any data gaps for all raw materials in a cosmetic product, including those used in such products notified or registered prior to CSAR, shall be filled before 1st May 2023.
There are two ways to report the information:

  1. Filer/registrant of the cosmetic product can obtain from its suppliers the Annex 14 information for each cosmetic ingredient and submit with filing/registration dossier.

  2. The supplier of the cosmetic ingredient can perform the notification for that ingredient on the MNPA safety information platform. A registration code will be generated which can be shared with downstream filer/registrants for use during the registration process of the finished cosmetic product.

As a fragrance manufacturer, Sozio is willing to provide the Annex 14 with the basic set of documents (SDS, IFRA, Allergens certificate) to downstream filer/registrants placing cosmetics on the Chinese market.
For the best-selling fragrances, Sozio authorizes its Chinese subsidiary to perform the ingredient data submission on the NMPA safety information platform on its behalf. Through this process the fragrance registration code will be generated and subsequently made available to appropriate downstream filer/registrants.

 

CHANGE FOR THE BETTER, WITH SOZIO SUPPORT

CSAR aims to encourage and support research and innovation of cosmetics to meet consumer needs, with advanced technology and management practices to improve the quality and safety of cosmetics through a combination of modern techniques. Under the premise of safety, more innovative technologies will be utilized in cosmetic R&D, stimulating the industries vitality and motivating scientific investigation and application. In addition, the positive policies in CSAR are hoped to boost enterprises’ interest in developing new ingredients and products with new efficacy claims.

Sozio fully supports customers facing this new regulatory challenge through provision of fragrance safety information by way of Annex 14 information, or by registering the best-selling fragrances directly, and providing the registration code. As the official text is only available in the Chinese language, the support of Sozio’s Chinese subsidiary offers an advantageous and comprehensive understanding of the regulation and Sozio’s obligations regarding CSAR requirements and compliance.

 

FOLLOW UP

If you need any further information about Vegan certifications, please reach out to us via email: regulatory@jesozio.com or through your designated Sales Representative.